Mr. Devansh is an Indian citizen and person of Indian origin who is living in the UK for the last 15 years. He comes to India every year for one…

CA Final · Direct Tax Laws and International Taxation · RTP · May 2025
Mr. Devansh is an Indian citizen and person of Indian origin who is living in the UK for the last 15 years. He comes to India every year for one month to visit his parents. For the rest of the year, he stays in UK. He has invested in shares of Alpha Ltd., Beta Ltd., and Delta Ltd. in convertible foreign exchange. Alpha Ltd. and Beta Ltd. are companies incorporated in GIFT IFSC, Gujarat, carrying on business for which it has been approved for setting up in such a Centre in a special economic zone. Delta Ltd. is a company incorporated in New Delhi. The dividend income of Mr. Devansh from Alpha Ltd., Beta Ltd. and Delta Ltd. during the P.Y. 2024-25 is 62,500,87,300 and - 21,800, respectively. The interest expenditure incurred by him during the P.Y.2024-25 on money borrowed for investment in these shares is 12,000,20,000 and - 7,000, respectively. Mr. Devansh has also lent foreign currency equivalent to 50 lakhs to Gamma Ltd., a company located in GIFT IFSC on 1st April, 2021. The rate of interest is 10% p.a. He has also made a deposit of foreign currency equivalent to 30 lakhs in IFSC banking unit of SEZ on 1st April, 2022. The rate of interest is 8% p.a. Dividend of 5,41,200 is due to be received in January, 2025 by Gamma Ltd. from Phi Ltd., which is also a company located in GIFT IFSC. The same was received on 28th January, 2025. Alpha Ltd. has started availing benefit of deduction u/s 80LA(1A) from A.Y. 2023-24 while Beta Ltd. has not started availing the benefit even though it has commenced operations on 1.4.2021. Alpha Ltd. furnished the declaration to the payers about the claim of deduction under section 80LA(1A)/(2) for the P.Y. 2024-25 From the information given above, choose the most appropriate answer of MCQs 1 to 6:
(A) ₹ 4,360
(B) ₹ 15,522
(C) ₹ 17,160
(D) ₹ 19,340

Suggested Answer and Working Notes:

Correct Answer: Option (D)

₹ 19,340

Topics: Transfer Pricing, Double Taxation Relief, Non-Resident Taxation

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