Lokesh, who is 50 years old, has been serving as the CEO of Platinum India Ltd. since April 1, 2019. His total income in India is derived from…
CA Final · Direct Tax Laws and International Taxation · MTP · May 2025
Lokesh, who is 50 years old, has been serving as the CEO of Platinum India Ltd. since April 1, 2019. His total income in India is derived from multiple sources. During the previous year 2024-25, he receives a salary of 23 lakhs before any standard deduction is applied. Additionally, he paid - 1,80,000 towards interest on loan borrowed for a self-occupied property. Furthermore, he receives - 1,60,000 as interest on bank fixed deposits. For the year ending 31st March 2025, Lokesh has also earned income from several sources in Country 'A'. He earned USD 25,000 from his business operations in Country A and received USD 4,500 as rent from a house property. Although he paid municipal taxes of USD 450 on the house property, these taxes are not deductible in Country A. Lokesh also earned a dividend of USD 10,000 from shares held in Country A, which was declared and paid in March 2025. Additionally, he realized a short-term capital gain of USD 5,000 from the sale of shares of companies registered in Country A, with the sale proceeds credited to his bank account outside India on 28th March 2025. India has DTAA with Country 'A' and the tax paid in Country 'A' is eligible for tax credit in India. The fiscal year for income-tax is the same both in India and Country 'A'. Rate of tax is 20% in Country 'A' in respect of all incomes. Income-tax was paid by Lokesh on 25.05.2025 for the incomes of the year ended 31st March 2025 in Country 'A'. Compute the total income and net tax liability of Lokesh for the A.Y. 2025-26. Assume Lokesh pays tax under default regime under section 115BAC. The TT buying rate of 1 USD on various dates: 28.02.2025= 70; 28.03.2025 = 70.50; 31.03.2025 = 71; 30.04.2025 = 72; and 25.05.2025 = 73.
Suggested Answer and Working Notes:
Computation of total income of Lokesh for A.Y. 2025-26 as per section 115BAC Since Mr. Lokesh is a resident in India for the P.Y.2024-25, his global income would be subject to tax in India. Therefore, income earned by him in Country A would be taxable in India. Particulars Amount Amount (₹) Salaries Salary from Platinum Ltd. 23,00,000 Less: Standard deduction u/s 16(ia) 75,000 22,25,000 Income from house property Let out property in Country A Gross Annual Value 1 USD 4,500 Less: Municipal taxes USD 450 Net Annual Value USD 4,050 Less: Deduction under section 24 - 30% of NAV USD 1,215 USD 2,835 [₹ 2,835 x 71, being the last day of previous year i.e., 31.3.2025 as per Rule 115] 2,01,285 Self-occupied property in India Loss from self-occupied property [Interest u/s 24(b) is not allowable in respect of self-occupied property under section 115BAC] 2,01,285 Profits and gains from business or profession Income from business in Country A [₹ 25,000 x 71, being the last day of previous year i.e., 31.3.2025 as per Rule 115] 17,75,000 Capital Gains Short term capital gains on sale of shares of companies registered in Country A [₹ 5,000 x 70, being the last day of the month immediately preceding the month in which the shares are transferred i.e., 28.2.2025 as per Rule 115] 3,50,000 Income from Other Sources Interest on bank fixed deposits 1,60,000 Dividend from shares held in Country A [₹ 10,000 x 70, being the last day of the month immediately preceding the month in which the dividend is declared i.e., 28.2.2025 as per Rule 115] 7,00,000 8,60,000 Gross Total Income/Total Income 54,11,285 Total Income (Rounded off) 54,11,290 1 Rental Income has been taken as GAV in the absence of other information relating to fair rent, municipal value etc. Computation of Net tax liability of Lokesh for A.Y.2025-26 Particulars Amount Upto 3,00,000 Nil 3,00,001 - 7,00,000 [i.e.,4,00,000 @5%] 20,000 7,00,001-10,00,000 [i.e.,3,00,000 @10%] 30,000 10,00,001-12,00,000 [i.e.,2,00,000 @15%] 30,000 12,00,001-15,00,000 [i.e.,3,00,000 @ 20%] 60,000 15,00,001-54,11,290 [i.e.,39,11,290 @ 30%] 11,73,387 13,13,387 Add: Surcharge@10% [Since total income exceed 50lakhs but does not exceed 1crore) 1,31,339 14,44,726 Add: Health & Education Cess@4% 57,789 15,02,515 Less: Foreign tax credit, being lower of - Tax payable in India @27.767% on 30,26,285, being income from house property of 2,01,285, business income of 17,75,000 plus capital gains of 3,50,000 plus dividend income of 7,00,000 [i.e - 15,02,515/54,11,290 x 100] = 27.767% 8,40,309 Tax paid in Country A@20% [$ 44,500 @20% x 72, being the rate on 30.4.2024, being the last day of the month immediately preceding the month in which tax is paid, i.e., May 2025] 6,40,800 6,40,800 Net tax liability 8,61,715 Net tax liability (Rounded off) 8,61,720
Topics: Double Taxation Relief
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