CA Final 2025: Capital Gains Solutions
CA Final 2025: Capital Gains Solutions
CA Final MAY/NOV-2025
Test Paper – 1 Solu?on
Topics: Tax rates, Capital Gain & IFOS
1.
(c) Nil and ₹ 95 lakhs, respectively
2.
(i) (c) ₹ 50 lakh is taxable as his business income (iii) (c) ₹ 38 lakh is taxable as short-term capital gains
No amount is taxable in the hands of Mr. ₹ 20 lakh is taxable under the head “Income from Other
(ii) (a) (iv) (b)
Rajesh Sources”
3.
(d) Long-term capital gains of Mr. Rajan ₹ 2,10,000; Long-term capital loss of Mr. Ravi ₹ 1,20,000
4.
(B) ₹ 2,15,13,050
5.
(i) (d) ₹ 1155 lakhs and ₹ 165 lakhs, respectively
(ii) (b) ₹ 45,90,300
(iii) (c) ₹ 1845 lakhs and ₹ 429.81 lakhs, respectively
6.
(d) Value of gold ring is taxable in the hands of Mr. Vikas but value of gold chain is not taxable in the hands of Ms. Kavya
7.
(i) (a) Short term capital gains ` 10,833
(ii) (c) ₹ 8,16,813
(iii) (a) ₹ 1,51,000
8.
(d) ` 81 lakhs
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Descrip)ve
1. Computa)on of “Capital Gains” of Mrs. Yuvika for A.Y.2025-26
Particulars ` (in lakhs) ` (in lakhs)
Capital Gains on sale of residential building
Actual sale consideration ` 810 lakhs
Value adopted by Stamp Valuation Authority ` 890 lakhs [Where the actual
sale consideration is less than the value adopted by the Stamp Valuation
Authority for the purpose of charging stamp duty, and such stamp duty value
exceeds 110% of the actual sale consideration, then, the value adopted by the
Stamp Valuation Authority shall be taken to be the full value of consideration
as per section 50C.
However, where the date of agreement is different from the date of
registration, stamp duty value on the date of agreement can be considered
provided the whole or part of the consideration is received by way of account
payee cheque/bank draft or by way of ECS through bank account or through
prescribed electronic modes on or before the date of agreement.
In this case, since advance of ` 80 lakh is received by RTGS, i.e., one of the
prescribed modes, stamp duty value on the date of agreement can be
adopted as the full value of consideration. However, in the present case since
stamp duty value on the date of agreement does not exceed 110% of the
actual consideration, actual sale consideration would be taken as the full
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value of consideration) 810.00
Gross Sale consideration (actual consideration, since stamp duty value on the
date of agreement does not exceed 110% of the actual consideration)
Less: Brokerage @1% of sale consideration (1% of ` 810 lakhs)
Net Sale consideration 8.10
Less: Indexed cost of acquisition
801.90
- Cost of vacant land, ` 80 lakhs, plus registration and other expenses i.e.,
` 8 lakhs, being 10% of cost of land [` 88 lakhs] 88.00
- Construction cost of residential building (` 100 lakhs)
Long-term capital gains 100.00 188.00
Since the residential house property was held by Mrs. Yuvika for more than
24 months immediately preceding the date of its transfer, the resultant gain 613.90
is a long-term capital gain]
Less: Exemption under section 54 130.00
Where long-term capital gains exceed ` 2 crore, the capital gain arising on
transfer of a long-term residential property shall not be chargeable to tax to
the extent such capital gain is invested in the purchase of one residential
house property in India, one year before or two years after the date of
transfer of original asset.
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2. Computation of capital gains chargeable to tax for PY 21-22 AY 22-23
Par)culars `
Par)culars `
Full value of consideradon received on sale of residendal house at Panchkula 3,25,00,000
Less: Cost of acquisidon [As per secdon 54, if the new residendal house
purchased (i.e., on 20.7.2022, in this case) is transferred within 3 years of its
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purchase (i.e., on 31.10.2024, in this case), and the cost of acquisidon of the
new house (i.e., ` 2,05,00,000) is higher than the long-term capital gain (i.e.,
1,13,77,273) then, the cost of acquisidon of such new residendal house shall
be reduced by long term capital gain exempted earlier, while compudng capital
gains on sale of the new residendal house] 91,22,727
[` 91,22,727 (`2,05,00,000 – `1,13,77,273)]
Long-term capital gain [Since the residendal house is held for more than 24 2,33,77,273
months]
Less: Exemp)on under sec)on 54
Purchase of new residendal house property in Delhi for ` 2,57,00,000 on
2.3.2025 i.e., within two years from 31.10.2024, being the date of transfer of
residendal house at Panchkula; exempdon restricted to long term capital gain,
2,33,77,273
since cost of new house exceeds long-term capital gains
Taxable long term capital gain Nil
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Comedy FMV 250.0000
Alepropy 1700.000
Assets
Assets SIS 1700.000712cal
2500.000
Asset 0900
Gift
ContentAsset otheric
[Link]
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Co Max
561271 2 Ireland
1 Items
FEEL
on
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Jewelry
Eoe30.0.00.000
a 8
6 7827668
hss
Exempts 218
5m
1119
fhf
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6442957
1116 55705
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Topic wise Test Papers of CA FINAL - Direct Tax – MAY/NOV - 25 Exams
Paper - 2
Topic: Income from Capital Gain, IFOS, Dividend, Liquidation & BuyBack
Total Marks: 45 Marks
Time Allowed: 75 minute
Questions:
(a) ` 80,50,000
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transfer of jewellery were ` 2,00,000?
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(b) ` 81,55,705
(c) ` 98,00,000
(d) ` 48,00,000
2. Mr. Ram, an Indian resident, purchased a residential house property at Gwalior on 28.05.1999 for ` 28.4
lakhs. The fair market value and the stamp duty value of such house property as on 1.4.2001 was ` 33.5
lakhs and ` 32.4 lakhs, respectively. On 05.02.2012, Mr. Ram entered into an agreement with Mr.
Byomkesh for sale of such property for ` 74 lakhs and received an amount of ` 3.9 lakhs as advance.
However, as Mr. Byomkesh did not pay the balance amount, Mr. Ram forfeited the advance. What would
be the indexed cost of acquisition of Mr. Ram if he sells the property on 22nd July 2024 ?
Cost Inflation Index for F.Y. 2001-02: 100; F.Y. 2024-25: 363
(a) ` 1,65,58,000
(b) ` 1,03,45,500
(c) ` 1,07,44,800 WE 3240.000 390000
(d) ` 1,17,61,200
2850.000 78 10345 50
CA BHANWAR BORANA BB VIRTUALS
2 Test Papers of CA Final - Direct Tax - MAY/NOV-25 Exams — Questions
3. Mr. X, aged 61 years, earned dividend of ` 12,00,000 from ABC Ltd. in P.Y. 2024-25. Interest on loan
taken for the purpose of investment in ABC Ltd., is ` 3,00,000. Income includible in the hands of Mr. X
for P.Y. 2024-25 would be -
(a) ` 12,00,000
1200000
(b) ` 9,60,000
(c) ` 9,00,000
4.
(d) ` 2,00,000
2TEur
Mr. Vikas transferred 600 unlisted shares of XYZ (P) Ltd. to ABC (P) Ltd. on 15.07.2024 for ` 3,50,000
when its fair market value was ` 5,15,000. The indexed cost of acquisition of shares for Mr. Vikas was
computed at ` 4,25,000.
5010 Determine the income chargeable to tax in the hands of Mr. Vikas and ABC (P) Ltd. in respect of the
above transaction.
16500
515000 (a) ` 90,000 chargeable to tax in the hands of Mr. Vikas as long-term capital gains and nothing is If
roof taxable in the hands of ABC (P) Ltd.
GA425L(b) ` 75,000 chargeable to tax in the hands of Mr. Vikas as long-term capital gains and nothing is
taxable in the hands of ABC (P) Ltd.
56N
(c) ` 90,000 chargeable to tax in the hands of Mr. Vikas as long-term capital gains and ` 1,65,000 is
taxable under the head “Income from other sources” in the hands of ABC (P) Ltd.
(d) ` 75,000 chargeable to tax in the hands of Mr. Vikas as long-term capital gains and ` 1,65,000 is
taxable under the head “Income from other sources” in the hands of ABC (P) Ltd.
5. Mr. Jay Acquired Market Linked debentures of ` 20,00,000 on 16/07/2019. On 10/12/2024 he transfers
such debentures at ` 28,00,000. What is the amount of capital gain on sale of MLD? CII of FY 19-20 is
289 and FY 24-25 is 363.__
(a) Dividend distribution tax is payable by Delta Ltd. There would be no tax on dividend received
by Mr. Ganesh and Mr. Rajesh in their individual hands
(b) Dividend distribution tax is payable by Delta Ltd. Further, dividend of ₹ 2.75 lakhs receivable
by Mr. Ganesh i.e., dividend in excess of ₹ 10 lakhs will be taxable at 10%
(c) Tax is deductible by Delta Ltd. before making payment of dividend. Also, the same shall be
CA BHANWAR BORANA BB VIRTUALS
Test Papers of CA Final - Direct Tax - MAY/NOV-24 Exams — Questions 3
taxable in the hands of both Mr. Ganesh and Rajesh at 10%
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(d) Tax is deductible by Delta Ltd. before making payment of dividend. The dividend income
would be included in the total income of both Mr. Ganesh and Rajesh and subject to tax in
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their hands at their respective slab rates
28
Compute Capital Gain and IFOS of Mr. Raghav for the A.Y. 2024-25 from the following details:
He was holding 30% equity shares in TSP (P) Ltd., an Indian company. The paid up share capital of company
as on 31st March, 2023 was ` 20 lakh divided into 2 lakh shares of` 10 each which were issued at a premium
of ` 30 each. Company allotted shares to shareholders on 1st October, 2014.
He sold all these shares on 30th April, 2024 for ` 60 per share. Equity shares of TSP (P) Ltd. are listed on
National Stock Exchange and Mr. Raghav has paid STT both at the time of acquisition and transfer of such
shares. FMV on 31.1.2018 was ` 50 per share.
On 12.2.2025, interest of fixed deposits with SBI of ` 1,00,000. On 30.4.2024,` 5,500 and on 30.12.2024, `
8,500 credited to interest on saving bank A/c with SBI Bank.
60.000 50 30 00 [Link]
ftp.t cost 64 9125200
9
2
55 L need
4 Test Papers of CA Final - Direct Tax - MAY/NOV-25 Exams — Questions
Question-4
Aries Tubes Private Ltd. went into liquidation on 1.6.2024. The company was seized and possessed of the
[Link] following funds prior to the distribution of assets to the shareholders:
Share Capital (issued on 1.4.2013)
`
5,00,000
Deemed Reserves prior to 1.6.2024 3,00,000
Excess realization in the course of liquidation 5,00,000
Total 13,00,000
There are 5 shareholders, each of whom received ` 2,60,000 from the liquidator in full settlement. The
shareholders desire to invest the resultant element of capital gain in long term specified assets as defined in
section 54EC. You are required to examine the various issues and advice the shareholders about their liability
to income tax.
900000
Question-5
GET ELA BREE B 30 300.00
[5 Marks]
Tax 23.296
Avimanyu, a resident individual held 25% equity shares in FMC Ltd, an unlisted Indian company. The
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company's paid up share capital as on 31st March, 2023 was 10,00,000 divided into 1,00,000 equity shares of `
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Ess
10 each issued at a premium of ` 20 each. The shares were allotted to the shareholders on 1st October, 2012.
The company had gone for buy back of 30% of its shares on 30th April, 2024 as per the provisions of the
Companies Act, 2013.
The company paid ` 60 per share on buy back.
Explain and compute the tax effect in the hands of FMC Ltd and Avimanyu. Would there be change in the tax
liability if FMC Ltd. was listed on a stock exchange.
[5 Marks]
101311
MR Gopal 1424254425 26
Computation of Canter gain Computam
ofTotalIncome
Froe [Link] 1714 V 51 1 2 [Link]
Hears
NI 12.50.0000 me
12.13 60
350000
2324 wife 426000
[Link]
CA BHANWAR BORANA
111 23 4 BB VIRTUALS
350000 363 36 006
Computation
ofTax liab s
7am 4101112
9 Tax 12 se without Index 10150000 12.57 1268750
b Tax
[Link] Note1 5600914 200 1120183 1120183
TICBINI
[Link] 250000
250000Unto500000 57 12500
Sooooo [Link] 20 112500
100dg
1232683
Gland offronetose
2 i) As per section 44AD, eligible assessee for this section are resident firms (excluding
LLP)/individual/HUF having Turnover/Gross Receipts upto Rs.2 Cr. and not in the
business of section 44AE, agency, commission and brokerage.
For the business of plying, hiring, leasing such goods carriage presumptive income
will be calculated as per Sec44AE.
44AE is applicable only if assessee owns Max 10 Vehicles.
Therefore, in the given case eligible firms for declaring income on presumptive basis
are AB & Co., LM & Co. and XY & Co.
ii) As per section 44AD, income on presumptive basis is Turnover/Gross Receipts *6%
(for account payee cheque/DD/ECS received upto due date of ROI) and for remaining
modes it is Turnover/GR *8%.
Therefore, in the given cases income will be calculated as follows -:
AB & Co.
Presumptive Income = (150+20) *6% + 30*8% = Rs. 12,60,000
Working Partner’s Salary and Interest shall not be deductible while computing
income as per Sec 44AD
PQ & Co.
Since sec 44AD is not applicable therefore book profits of Rs.4,50,000
M/s TPS have not got the books of a/c audited so they can opt for presumptive
[Link] 7,20,000 i.e. [(6% of 80,00,000) +(8% of 30,00,000)]
4. Interest allowed on payment basis as per section 43B. Restructuring of Interest
into loan is not treated as actual payment.
Topic wise Test Papers of CA Final - Direct Tax – MAY/NOV-25 Exams
Topic: PGBP
Answers:
1. Answer : C
2. Answer
(i) D
(ii) A
(iii) C
(iv) C
(v) B
3. Answer: C
4. Answer: D
(e) Fees paid to directors without deducting tax at source [30% of `1 30,000 11,50,000
lakh] [Disallowance@30% would be attracted u/s 40(a)(ia) for non-
deduction of tax at source from director’s remuneration on which tax
is deductible u/s 194J]
1,63,50,000
Less: Items credited but to be considered separately/Expenditure to
be allowed
(i) Profit on sale of plot of land to 100% subsidiary 12,00,000
[Short-term capital gains arises on sale of plot of land held for less
than 24 months. However, in this case, since the transfer is to a 100%
subsidiary company and the subsidiary company is an Indian
company, the same would not constitute a transfer for levy of capital
gains tax as per section 47(iv).
Since this amount has been credited to the statement of profit and
loss, the same has to be deducted for computing business income).
(ii) Depreciation 5,00,000
[Depreciation allowable under the Income-tax Act, 1961 is `15 lakhs
whereas the depreciation as per books of account debited to the
statement of profit and loss is `10 lakhs. Hence, the additional
amount of `5 lakhs has to be deducted while computing business
income]
(iii) Additional compensation received from State Government [Since the 10,00,000
additional compensation has been received pursuant to an interim
order of the Court, the same would be deemed as income chargeable
to tax under the head “Capital Gains” in the year of final order as per
section 45(5). Since the compensation has been credited to the
CA BHANWAR BORANA BB VIRTUALS
Test Papers of CA Inter - Direct Tax - MAY/NOV-25 Exams — Answers 3
Solution 2:
2 It is assumed that interest is on any loan or borrowing from any public financial institution or a State Financial
Corporation or a State Industrial Investment Corporation or a deposit taking non-banking financial company or
systemically important non-deposit taking non-banking financial company or a scheduled bank or co-operative bank other
than a primary agricultural credit society or a primary co-operative agricultural and rural development bank
3 As decided in CIT v. K and Co. (2014) 364 ITR 93 (Del)
(h) Dividend received from foreign company 2,50,750
Dividend received from foreign company is taxable
under “Income from other sources”. Since the same
has been credited to the profit and loss account, it
has to be deducted while computing business
income.
10,30,750
2,17,04,250
Less: Depreciation as per Income-tax Act, 1961
Normal depreciation [Refer Note below for
alternative]
- Depreciation on assets other than on air 32,50,000
compressor, air pollution control equipment & lorries
stated in A (2), (3) & (4)
- On Air Compressor machine [74,00,000 x 15%] 11,10,000
- On Air Pollution Control Equipment [23,45,000 x 9,38,000
40%]
- On Lorries for transporting goods to sales depots 7,12,500
[95,00,000 x 15% x 50%, since it is used for less
than 180 days]
- On Machine imported from Germany [Nil, since it is Nil
not installed in P.Y. 2024-25]
60,10,500
Additional depreciation
- On Air Compressor machine [74,00,000 x 20%] 14,80,000
- On Air Pollution Control Equipment [23,45,000 x 4,69,000 19,49,000
20%]
1,37,44,750
II Income from Other Sources
Dividend received from foreign company 2,50,750
[Dividend received from a foreign company is chargeable
to tax under the head” Income from other sources”.
` 15,000, being an expense other than interest payment
is not allowable as deduction from dividend income.]
Gross Total Income/ Total Income 1,39,95,500
Computation of Tax payable
Tax on ` 1,39,95,500 @30% (since the turnover exceed 41,98,650
` 400 crores in the P.Y. 202 -2 )
Add: Surcharge @ 7% (since total income exceeds ` 1 2,93,906
crore but less than ` 10 crore)
44,92,556
Add: Health and Education cess @ 4% 1,79,702
Tax Payable 46,72,258
Tax Payable (Rounded off) 46,72,260
Note – The above solution has been worked out on the assumption that scrap value of
machine ` 7,80,000 has already been adjusted in computing the depreciation of ` 32,50,000.
However, if it is assumed that adjustment in respect of scrap value of machine is not
considered in the depreciation amount of ` 32,50,000, the business income, total income and
tax payable would be ` 1,38,61,750, ` 1,41,12,500 and ` 47,11,320, respectively.
Question:1
As per Section 115UB, PGBP income of investment funds is taxable in hands of investment
funds. As per amendment made by FA 2019, Losses other than PGBP of Investment Fund shall
be distributed to unit holders and unit holder can set off and carry forward such loss if unit
holder hold such units for 12 months or more. So, long term capital loss of Rs. 3 Crores shall
be carrying forward by unit holders.
Question:2
(i) The business trust has to deduct tax at source under section194LBA– - @10%, on
interest component of income distributed to resident unit holders; and - @5%
(plus cess), on interest component of income distributed to non- corporate Non-
resident unit holders and foreign companies. Interest component of income
distributed to unit holders is taxable in the hands of the unit holders – @5%, in
case of unit holders, being non-corporate non- residents or foreign companies;
and at normal rates of tax, in case of resident unit holders.
Therefore, tax is deductible at 10% for Mr. X (Resident) and 5.2% (including HEC)
for Mr. Y (Non-resident).
(ii) As per section 115UA(2), the business trust is liable to pay tax@15% under section
111A in respect of short-term capital gains on sale of listed shares and MMR for
sale of developmental properties.
(iii) Section 10(23FC) - Interest & Dividend from SPV shall be fully exempt in hands of
REIT. Any other income (except interest from SPV & Rental income from REIT)
received by unit Holders for Business Trust shall be exempt in hands of Unitholders
u/s 10(23FD). Dividend taxable only when SPV paid taxes as per 115BAA.
Therefore, no tax payable by REIT or unit holder.
(iv) Since, tax is paid by SPV as per section 115BAA. Dividend will be taxable in hands
of unitholder. Dividend exempt in hands of business trust due to its pass-through
status.
(v) Such interest is taxable at maximum marginal rate, in the hands of the Business
trust, asper section 115UA(2). However, there would be no tax liability in the
hands of the unit holders on the interest component of income distributed to
them, by virtue of section 10(23FD).
(vi) The distributed income or any part thereof, received by a unit holder from the
REIT, which is in the nature of income by way of renting or leasing or letting out
any real estate asset owned directly by such REIT is deemed income of the unit
holder as per section 115UA(3). The business trust has to deduct tax at
source@10% under section 194LBA in case of distribution to a resident unit holder
and at rates in force in case of distribution to a non- resident unit holder.
Question:3
As per Section 115UB, PGBP income of investment funds is taxable in hands of investment
funds.
Section 115UB – All income received by unit holders from investment fund are taxable in
hands of unit holders (except PGBP).
As per amendment made by FA 2019, Losses other than PGBP of Investment Fund shall be
distributed to unit holders and unit holder can set off and carry forward such loss if unit holder
hold such units for 12 months or more.
(i) As per taxation on investment fund, PGBP income of Rs.14,00,000 will be taxable
in the hands of investment fund and remaining income of Rs.28,00,000 (Capital
Gain-21,00,000 + IFOS – 7,00,000) will be taxable in the hands of unit holder i.e.
Rs.80,000 to each holder (28,00,000/35).
(ii) As per taxation on investment fund, PGBP income of Rs, 14,00,000 will be taxable
@30%plus HEC 4% since it is LLP.
(iii) As per taxation on investment fund PGBP loss of Rs. 4,00,000 (PGBP loss 10,00,000
– IFOS6,00,000) will be carried forward by Investment Fund II and since units have
been hold by holders for a period of atleast 12 months therefore capital loss of
Rs.40,000 (20,00,000/50) can be c/f by each unit holder.
(iv) As per taxation on investment fund PGBP income will be Rs. 11,00,000 for A.Y. 24-
25 as PBGP income for current year is Rs. 15,00,000 and carried forward loss of
previous year is Rs.4,00,000.
Question:4
Business Trust
Rental income received by unitholder from REIT and interest received by unitholder from
business trust (which was received from SPV) shall be taxable in hands of unitholder.
Therefore, taxable amount = 18 lakh x 10% share = 1.8 lakh.
Securitisation Trust
Section 115TCA - Any income accruing or arising to, or received by, a person, being an investor
of a securitisation trust, out of investments made in the securitisation trust, shall be
chargeable to income-tax in the same manner as if it were the income accruing or arising to,
or received by, such person, had the investments by the securitisation trust been made
directly by him.
Investment Fund
Section 115UB – All income received by unit holders from investment fund are taxable in
hands of unit holders (except PGBP).
Loss other than PGBP is allowed to be carried forward by Unit holder.
Therefore, taxable amount = 2 lakh x 5% share = 0.10 lakh. Share in capital loss = 12.50 lakh
x5% share = 0.625 lakh.
Question:5
Section 35AD - 100% deduction is allowed in respect of all capital expenses except
a) Land b)Goodwill c) Financial Instruments.
Therefore, deduction = 65 lakhs.
(ii)
A : 37.50 Lakhs
(iii)
Taxable Income
Add: Deduction u/s 10AA : 132.50 Lakhs
(iv) Tax as per normal provision was higher. Therefore, no AMT credit will be there.
(v) As per section 44AD, income on presumptive basis is Turnover/Gross Receipts *6% (for
account payee cheque/DD/ECS received upto due date of ROI) and for remaining modes, it is
Turnover/GR *8%.
Therefore, in the given cases income will be calculated as follows -: 190 lakhs*6% + 10
lakhs*8% = 12.20 lakhs.
(vi) Section 44AB - Every person, carrying on business shall, if his total sales, turnover or gross
receipts, as the case may be, in business exceed or exceeds one crore rupees in any previous
year shall get its books audited.
Since, income declared as per books is less than presumptive profit, hence, Audit is
mandatory.
Question:6
Question:7
Question 9
Question 8
All the best, Do the Best, God will do the rest 😊
Topic wise Test Papers of CA Final - Direct Tax – MAY/NOV-25 Exams
Answers:
1. Answers:
(i) D
(ii) B
(iii) D
(iv) D
(v) D
(vi) C
2. Answer: D
3. Answer: A
4. Answer: C
5. Answer: A
Descriptive
1.
Computation of total income and tax liability of Miss Vivitha for the A.Y. 2025-26
Particulars ` `
Indian Income [Income from playing snooker tournaments in India] 19,20,000
Foreign Income [Income from playing snooker matches in country L] 12,00,000
Gross Total Income 31,20,000
Less: Deduction under Chapter VIA `
Deduction u/s 80C
Life insurance premium of `1,10,000 paid during the previous year 1,10,000
deduction, is within the overall limit of `1.5 lakh. Hence, fully allowable
as deduction
Deduction u/s 80D
Medical insurance premium of `30,000 paid for her father aged 62
years. Since her father is a senior citizen, the deduction is allowable to
a maximum of `50,000 (assuming that her father is also a resident in
2.
Computation of total income and tax liability of Smt. Laxmi for A.Y. 2025-26
Particulars ` `
Income from house property
Rental income from property at Mumbai (computed) 1,80,000
Less: Loss from let out property at Chennai (4,40,000) (2,60,000)
Profits and gains from business and profession
Business income in India 6,00,000
Business income in Country B 4,00,000
10,00,000
3.
Determination of Gross Margin of Comparable Uncontrolled transaction i.e., of SAK Ltd.
Particulars Amt in USD
Direct Cost (USD 100 x 8 hours x 15 days) 12,000
Indirect Cost (USD 200 x 8 hours x 15 days) 24,000
Total Direct and Indirect cost 36,000
Add: Cost of warranty [1% of direct cost of USD 12,000] 120
Total Cost 36,120
4.
LMN Ltd, an Indian company and ABC Ltd., a Canadian company, are deemed to associated
enterprises as per section 92A(2), since ABC Ltd. holds shares carrying 35% of the voting power (i.e.,
not less than 26% of voting power) in LMN Ltd. Further, the transaction of developing software and
providing consultancy services (both onsite and offsite) fall within the meaning of “international
transaction” u/s 92B. Hence, transfer pricing provisions would be attracted in this case.
30%
Add: Cost of credit to ABC Ltd. [LMN Ltd has provided credit of 1 month to ABC
Ltd. but not to the unrelated party. Therefore, adjustment for the cost of such
credit has to be carried out to arrive at the ALP] [(2% of 50%, being gross profit]
1%
Arm’s length gross profit mark up to cost
Cost incurred by LMN Ltd. for executing ABC Ltd.’s work 31%
2,25,000
Add: Adjusted gross profit (` 2,25,000 x 31%) 69,750
Arm’s length billed value 2,94,750
Less: Actual Billed Income from ABC Ltd. (` 1800 x 120 man hours) 2,16,000
Total Income of LMN Ltd to be increased by 78,750