Mr. Ramakant Gupta, a practicing Chartered Accountant in Delhi, is engaged in Taxation planning and consultancy for his clients. His client GBR…

Mr. Ramakant Gupta, a practicing Chartered Accountant in Delhi, is engaged in Taxation planning and consultancy for his clients. His client GBR Inc., a country M based foreign company, is carrying on the business of manufacture and sale of artificial jewellery under the brand name "Kangan". For expansion in Indian market, it used the online advertisement services of M/s. Lima Inc., a country Z based foreign company. During the previous year 2024-25, GBR Inc. paid 7 lakhs to Lima Inc. for such services. GBR Inc. has a permanent establishment in India but Lima Inc. has no permanent establishment in India. Mr. Ramakant Gupta is a member of Kikli Foundation, an education institution and a registered trust under section 12AB of the Income-tax Act, 1961. The trust has made payment to an advocate of 5,90,000 (including GST of 90,000) for providing services relating to a pending case of the Trust at High Court on 20.12.2024. The trust is following mercantile system of accounting. In May 2024, the trust paid salary payable for March 2024 amounting to 15,00,000 and Electricity Bill payable for the months of February and March 2024 amounting to 3,60,000. Mr. Ramakant Gupta sold 1000 Mitcoins, a virtual digital asset to Mr. Priyal on 20.11.2024 for a consideration of 340 per Mitcoin. Mr. Priyal is employed in ABC Limited at monthly salary of 1,20,000 per month during F.Y. 2024-25. Mr. Priyal has no other source of income. Please answer the following questions 6 to 9 with regard to above facts and Income-tax Act, 1961.