WorkIndex/Faq Section 87a Portal Denial
Case Study

Faq Section 87a Portal Denial
Landmark Court Judgment Analysis

Faq Section 87a Portal Denial needs detailed legal review and fact-matching before you rely on it. Compare top compliance and legal experts on the WorkIndex work index.

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Last fact-checked: 2026-06-25
Duplicate checked
Official-source cautious
India specific
Dispute Details

Facts & Lower Court History

  • Facts: Taxpayers claimed the Section 87A rebate (up to ₹25,000/₹60,000) against tax payable on short-term capital gains on listed shares under Section 111A.
  • Lower Court History: The Income Tax e-filing portal automatically disallowed the rebate on Section 111A gains. Taxpayers appealed to the ITAT (e.g. Surat ITAT).
  • Key Issues: Whether Section 87A rebate is available against tax calculated at special rates under Section 111A, and whether the portal's automated disallowance is legal.
Court Ratio

Legal Principles & Ratio Decidendi

  • Rebate Availability: ITAT rulings clarified that Section 87A rebate applies to the total tax payable. The only exception specified in the law is Section 112A (LTCG).
  • Literal Interpretation: Since Section 87A does not explicitly exclude Section 111A or other special rate incomes, the rebate must be allowed on those taxes.
  • Portal Limitations: The automated calculations on the e-filing portal cannot override the clear provisions of the Income Tax Act.
Key Evidence

Agreements & Filings Evaluated

  • ITR Acknowledgment: Computation sheets showing total income and tax calculated under Section 111A.
  • Demand Notices: Intimations under Section 143(1) raising tax demands due to disallowance of Section 87A.
  • ITAT Orders: Certified copies of tribunal rulings directing the Assessing Officer to allow the rebate.
Action Points

Practical Mitigation & Compliance Steps

  • Check Section 143(1) Demands: Review all automated tax intimations to see if Section 87A rebate was incorrectly disallowed.
  • File Rectification u/s 154: Submit a online rectification request on the portal citing the ITAT rulings to correct the calculation.
  • File Appeal if Needed: If rectification is rejected, file an appeal before the CIT(Appeals) within 30 days of the order.