Mr. Sarthak, an Indian citizen aged 51 years, left India for the first time on 1st April 2020 to settle in Country Y. But owing to some personal…

Mr. Sarthak is a resident in India for A.Y.2024-25, since his stay in India in the P.Y.2023-24 is for 305 days which exceeds the minimum required stay of 182 days in that previous year. Also, his stay in India must be more than 730 days in the immediately preceding seven years, and he must be resident in 7 years (P.Y.2013-14 to P.Y.2019-20) out of 10 years immediately preceding P.Y.2023-24, since he left India for the first time on 1st April, 2020. Hence, he is resident and ordinarily resident in India for A.Y.2024-25. Accordingly, his global income would be subject to tax. He would, however, be entitled for deduction under section 91 in respect of doubly taxed income earned in Country Y. Computation of total income of Mr. Sarthak for A.Y.2024-25 Particulars Particulars ₹ Income from House Property [Residential property in Country Y] Annual Value 4 ($ 32,000 x 75, exchange rate on 31.3.2024) 24,00,000 Less: Deduction under section 24 – 30% of NAV 7,20,000 16,80,000 Profits and Gains of Business or Profession Income from business in India 6,20,000 Income from Other Sources Dividend from Indian company [₹ 2,25,000 x 100/90] 2,50,000 Interest on savings bank account with SBI 13,500 2,63,500 Gross Total Income 25,63,500 Less: Deduction under Chapter VIA Under section 80TTA – Interest on savings bank account (actual interest of 13,500 or - 10,000, whichever is lower) 10,000 Total Income 25,53,500 Computation of net tax liability of Mr. Sarthak for A.Y.2024-25 Particulars ₹ Tax on total income [30% of 15,53,500 +1,12,500] 5,78,550 Add: Health and Education cess@4% 23,142 6,01,692 4 Rental Income has been taken as GAV in the absence of other information relating to fair rent, municipal value etc. Less: Deduction under section 91 (See Working Note below) Net Tax Liability Net Tax liability (rounded off) Working Note: Calculation of deduction under section 91 Particulars ₹ Average rate of tax in India [i.e.,6,01,692/25,53,500x100] 23.56% Average rate of tax in country Y [20% of $ 23,000 ($ 32,000 - $ 9,000) = $ 4,600/$ 32,000 x 100 = 14.375% 14.375% Doubly taxed income Income from house property 16,80,000 Deduction u/s 91 on 16,80,000 @14.375% (being the lower of average Indian tax rate (23.56%) and foreign tax rate (14.375%)] 2,41,500