On 1.4.2023, Focus Ltd., an Indian company, borrowed 50 crores@ 9.5% p.a. from Max Inc., a US entity, thereby increasing its total borrowings to 65…
CA Final · Direct Tax Laws and International Taxation · MTP · November 2024
On 1.4.2023, Focus Ltd., an Indian company, borrowed 50 crores@ 9.5% p.a. from Max Inc., a US entity, thereby increasing its total borrowings to 65 crores. The said loan is guaranteed by Hik Inc., another US entity. The place of effective management of both Max Inc. and Hik Inc. is in the USA. The book value of total assets of Focus Ltd. is 180 crores. Focus Ltd. imported turbo equipment worth 30 crores from Hik Inc. Import duty of 4.50 crores on the same was paid by Focus Ltd. The equipment was sold to T Ltd., an unrelated party for 40 crores. Normal GP margin of Focus Ltd. in similar uncontrolled transaction is 20%. Net profit of Focus Ltd. of A.Y.2024-25 was 8 crores after debiting interest of 6 crores (out of which - 1.25 crores interest pertaining to local borrowings), depreciation of 2.5 crores and income tax of 1.5 crores. Based on the facts of the above case scenario, choose the most appropriate answer to Q. 1 to 6 below:
Suggested Answer and Working Notes:
Correct Answer: Option (A)
₹ 6,65,00,000
Topics: Transfer Pricing, Double Taxation Relief, Non-Resident Taxation
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