Narmada Ltd. is engaged in the business of manufacturing car spare parts since 1 st April 2021. Its statement of profit and loss shows a net profit…
CA Final · Direct Tax Laws and International Taxation · MTP · May 2025
Narmada Ltd. is engaged in the business of manufacturing car spare parts since 1 st April 2021. Its statement of profit and loss shows a net profit of 350 lakhs for the year ended 31-03-2025, after debiting and crediting the following items: Fees of 1 lakh paid to independent directors for attending Board meeting without deduction of tax at source under section 194J.The opening and closing stock for the year were 200 lakhs and 255 lakhs, respectively. They were overvalued by 10%.Depreciation provided in accounts as per straight line basis 50 lakhs. 9 lakhs contribution to a National Laboratory approved under section 35(2AA).GST of 2.10 lakhs, pertaining to P.Y.2024-25, was paid on 27-12-2025.The company has also purchased goods of 63 lakhs from M/s. Saraswati Ltd. in which directors have substantial interest. The market value of the goods is 58 lakhs.The company has made cash payments for purchases of 5 lakhs on 17-08-2024 due to cash demanded by the supplier. It also made cash payments to transport operator for hiring of lorry on the following dates: 06-06-2024 -40,000; 03-07-2024 -35,000; 15-01-2025 -52,000.The company has incurred legal expenses of 5 lakhs and 4 lakhs for issue of bonus shares and for issue of right shares, respectively.Donation paid to a registered political party by way of cheque 17 lakhs Additional Information: (i) Normal depreciation allowable as per the Income-tax Rules, 1962 is 62 lakhs. (ii) A debt of 4 lakh was claimed as bad debt in the previous year 2022-23. A sum of 2 lakh was recovered during the P.Y. 2024-25. The effect of recovery of bad debt was not given in books of account. The total turnover of the company for previous year 2022-23 was 390 crores and for financial year 2023-24405 crores. You are required to compute total income of the company as per Income-tax Act, 1961 for the Assessment Year 2025-26 indicating reasons for treatment of each item, assuming that the company has not opted for special provisions under section 115BAA or 115BAB. Ignore MAT provisions.
Suggested Answer and Working Notes:
Computation of Total Income of Narmada Ltd. for the A.Y.2025-26 Particulars Amount (₹) Profits and Gains from Business and Profession Net profit as per profit and loss account 3,50,00,000 Add: Items debited but to be considered separately or to be disallowed Fees paid to directors without deducting tax at source [Disallowance@30% would be attracted under section 40(a)(ia) for non-deduction of tax at source from director's remuneration on which tax is deductible under section 194J] 30,000 Depreciation provided on straight line basis [Depreciation provided in the accounts on straight line basis (i.e.,50 lakhs) has to be added back] 50,00,000 Contribution to a National Laboratory [Contribution to a National Laboratory under section 35(2AA) qualifies for deduction@100%]. Nil GST liability [GST liability of 2.10 lakhs would attract disallowance under section 43B, since it was paid only on 27.12.2025 (i.e., after the due date of filing return of income of A.Y.2025-26). It would be allowed in the year of payment (i.e., P.Y.2025-26). Hence, it has to be added back for computing business income] 2,10,000 Disallowance under section 40A(2) for excess payment to related person [Saraswati Ltd. is a related person under section 40A(2), since the directors of Narmada Ltd. have substantial interest in Saraswati Ltd. Therefore, excess payment of 5lakh to Saraswati Ltd. for purchase of goods would attract disallowance under section 40A(2).] 5,00,000 Disallowance under section 40A(3) for payment exceeding - 10,000 made in cash for purchases and expenditure [Cash payments exceeding - 10,000 a day attracts disallowance under section 40A(3). Accordingly, cash payment of 5lakhs made on 17-8-2024 would attract disallowance under section 40A(3), even if such payment is made due to demand of supplier] 5,00,000 Disallowance under section 40A(3) for cash payment exceeding - 35,000 in a day to transport operators for hiring of lorry [In respect of cash payments to transport operators, a higher limit of 35,000 per day is permissible. Therefore, cash payment of 35,000 on 03-07-2024 would not attract disallowance under section 40A(3). However, cash payments of 40,000 and - 52,000 on 06-06-2024 and 15-01-2025, respectively, would attract disallowance under section 40A(3) since the same exceeds - 35,000 per day] 92,000 Legal expenses for issue of bonus shares [There is no fresh inflow of funds or increase in capital employed on account of issue of bonus shares and there is only reallocation of the company's fund. Consequently, since there is no increase in the capital base of the company, legal expenses of 5lakhs in connection with issue of bonus shares is revenue expenditure and is hence, allowable as deduction. It has been so held by Apex Court in case of CIT vs. General Insurance Corpn. (2006) 286 ITR 232. Legal expenses for issue of right shares [4lakhs, being legal expenses in relation to issue of rights shares results in expansion of the capital base of the company and is, hence, a capital expenditure. Therefore, the same is not allowable as deduction. It has been so held in Brooke Bond India Ltd. v. CIT (1997) 225 ITR 798 (SC)] 4,00,000 Donation to a registered political party [Donation paid to a political party is not an allowable expenditure under section 37 since it is not laid out wholly or exclusively for the purposes of business or profession. Hence, the same has to be added back while computing business income. 17,00,000 Bad debt written off earlier, recovered now [The amount of bad debt written off earlier when recovered subsequently, such recovery is taxable under section 41(4)] 2,00,000 86,32,000 4,36,32,000 Less: Items credited but to be considered separately or to be allowed/ Expenditure to be allowed Depreciation allowable under the Income-tax Act, 1961 [Depreciation calculated as per Income-tax Rules, 1962 (i.e.62 lakhs) is allowable as deduction under section 32] 62,00,000 Over-valuation of stock [55lakhs x 10/110] [The amount by which stock is over-valued has to be reduced for computing business income.50 lakhs, being the difference between closing and opening stock, has to be adjusted to remove the effect of over-valuation] 5,00,000 67,00,000 Gross Total Income 3,69,32,000 Less: Deduction under Chapter VI-A Donation to registered political party [under section 80GGB] [Donation made by a company to a political party is allowable deduction under section 80GGB from gross total income, subject to the condition that payment is made otherwise than by way of cash. Since the donation is made by cheque the same is allowed as deduction under section 80GGB] 17,00,000 Total Income 3,52,32,000 Computation of tax liability of Narmada Ltd. for A.Y.2025-26 Particulars ₹ Tax@25% on total income of 3,52,32,000 [Since the total turnover or gross receipt in P.Y. 2022-23 ≤ 400 crore] 88,08,000 Add: Surcharge@7% (since total income exceeds 1crore but does not exceed 10crores) 6,16,560 Tax payable including surcharge 94,24,560 Add: Health and Education cess@4% 3,76,982 Total tax payable 98,01,542 Tax payable (Rounded off) 98,01,540
Topics: Profits and Gains of Business or Profession
Related Questions in this Topic
- Answer any two of the following three sub-parts (i), (ii), (iii) on the basis of decided case laws, bringing out the fol...
- P and R, are individuals, aged 28 years and 30 years respectively, who constitute an Association of Persons, sharing pro...
- Sheetal Industries Ltd. engaged in production and marketing of diversified products was incorporated in the year 2005. T...
- The net profit of Mahi Ltd. as per its statement of profit and loss for the year ended 31.03.2026 amounted to ₹ 27,22,00...
- M/s Strong Private Limited is a domestic company engaged in the business of manufacturing steel. The statement of Profit...