Mr. Pradhyuman, aged 48 years, a resident individual has furnished the following details of income earned during the previous year 2024-25: India…

CA Final · Direct Tax Laws and International Taxation · MTP · May 2025
Mr. Pradhyuman, aged 48 years, a resident individual has furnished the following details of income earned during the previous year 2024-25: India (i) Income from a sole-proprietary business in Indore 80 lakhs. (ii) Share of profit from a partnership firm in Bhopal 20 lakhs. Country G (iii) Agricultural Income (gross) from tea gardens of CGD 40000. Taxable @20%. (iv) Brought forward business loss of F.Y.2019-20 in Country G was CGD 5,200 which is not permitted to be set off against other income as per the laws of that country. Country M (v) Dividend income (gross) of CMD 30,000. Taxable @10%. (vi) Rental Income of CMD 52,000 from house property. Taxable @15%. CMD 6,000 paid towards Municipal taxes in Country M. Municipal taxes are not allowed as deduction in Country M. Other Information Mr. Pradhyuman has deposited - 1,50,000 in public provident fund and paid medical insurance premium of 28,000 by account payee cheque to insure the health of himself and his wife (aged 48 years).India has no DTAA with Country G and Country M. Compute total income and tax liability of Mr. Pradhyuman for the A.Y. 2025-26 after providing for deduction under section 91, assuming that 1 CGD/CMD = 70. Mr. Pradhyuman is opting out of the default tax regime and paying tax under normal provisions of the Act.

Suggested Answer and Working Notes:

Computation of total income and tax liability of Mr. Pradhyuman for A.Y. 2025-26 Particulars Particulars ₹ Income from house property Gross annual value 1 of house property in Country M [CMD 52,000 x 70/CMD] 36,40,000 Less: Municipal taxes [CMD 6,000 x 70/CMD] 4,20,000 Net Annual value 32,20,000 Less: Deduction @30% 9,66,000 22,54,000 Profits and gains from business and profession Income from sole proprietary concern in India 80,00,000 Share of profit from a partnership firm in India of 20lakhs, is exempt under section 10(2A) Nil Business profit 80,00,000 Less: Business Loss 2 in Country G (CGD 5200 x 70/CGD) 3,64,000 76,36,000 Income from Other Sources Agricultural income from tea gardens in Country G, is taxable in India (CGD 40000 x 70/CGD) 28,00,000 Dividend income from Country M (CMD 30000 x 70/CGD) 21,00,000 49,00,000 Gross Total Income 1,47,90,000 Less: Deductions under Chapter VI-A Under section 80C [deposit in PPF] 1,50,000 Under section 80D [Medi-claim premium paid - 28,000, restricted to 25,000] 25,000 1,75,000 Total Income 1,46,15,000 Tax on total income Tax on 1,46,15,000 [(30% x 1,36,15,000) plus - 1,12,500] 41,97,000 Add: Surcharge@15%, since total income exceeds 1crore but does not exceed 2crore 6,29,550 48,26,550 Add: HEC@4% 1,93,062 50,19,612 Average rate of tax in India [i.e.,50,19,612/1,46,15,000 x 100] 34.3456% Rebate u/s 91 in respect of income in Country G Average rate of tax in Country G 20% Doubly taxed income [₹ 28,00,000 - 3,64,000] 24,36,000 Rebate under section 91 on 24,36,000 @20% (lower of average Indian tax rate and rate of tax in Country G) 4,87,200 Rebate u/s 91 in respect of income in Country M Average rate of tax in Country M [CMD 3,000 (30,000 x 10%) + CMD 7800 (52,000 x 15%)/ CMD 82,000] x 100 13.1707% Doubly taxed income [₹ 22,54,000 +21,00,000] 43,54,000 Rebate under section 91 on 43,54,000 @13.1707% (lower of average Indian tax rate and rate of tax in Country G) 5,73,452 Tax liability in India 39,58,960 1 In absence of any information regarding fair rent and standard rent, actual rent is considered as gross annual value. 2 Since the eight year has not expired from the assessment year in which such business loss was incurred, such business loss can be set-off against current year business income.

Topics: Double Taxation Relief

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