The Statement of Profit & Loss of Tirupati Private Ltd., a domestic company engaged in manufacturing, shows net profit of 1,07,00,000 for the…

CA Final · Direct Tax Laws and International Taxation · RTP · May 2025
The Statement of Profit & Loss of Tirupati Private Ltd., a domestic company engaged in manufacturing, shows net profit of 1,07,00,000 for the financial year ended on 31st March, 2025, after debit/credit of the following items. A. Credited to the Statement of Profit and Loss: (i) Rent received from vacant land - 2,55,000 (ii) Rent received (gross) from a commercial property owned by the company - 5,30,000 (Tax deducted by tenant @ 10%) (iii) Interest received on income tax refund - 48,000 (iv) Profit on sale of plot - 8,00,000. (v) Dividend from ABC Inc., New York, a wholly owned subsidiary in February, 20256,00,000 B. Debited to the Statement of Profit and Loss: (i) Depreciation charged to the Statement of Profit and Loss - 11,86,000. (ii) Donation of 85,000 paid to Swachh Bharat Kosh. (iii) Actual contribution to the pension scheme of employees:1,90,000 (iv) Payment made to transporter - 68,000 by account payee cheque, but no tax has been deducted at source. (Transporter is having PAN and furnished declaration that he is covered under section 44AE and not having more than 10 goods carriages at any time during the previous year). (v) Bonus to employees - 4,48,000. However, payment was made on 18th December, 2025. (vi) Provision made for income-tax 4,20,000 (including interest of 70,000 thereon) (vii) Contribution of 1,00,000 to a University approved and notified under section 35(1)(ii). (viii) Interest of 1,50,000 on loan borrowed for acquiring shares in ABC Inc., New York Additional information: (1) Depreciation as per the Income-tax Act, 196118,00,000. However, while calculating such depreciation, rate applicable to computers has been adopted for (i) accessories like printers and scanners, and (ii) EPABX. The written down value of these items as on 01.04.2024 is given below: (a) Printers and Scanners - 3,00,000 (b) EPABX 5,00,000 (2) Additional depreciation on plant and machinery purchased for 34,00,000 on 18th November, 2024 has not been considered while calculating depreciation as per Income-tax Act, 1961 as above. (3) Provision for audit fee - 1,00,000 was made in the books for the year ended on 31st March, 2024 without deducting tax at source. Such fee was paid to auditors in October 2024 after deducting tax at source under Section 194J and tax so deducted was deposited on 12th December, 2024. (4) During the financial year 2023-24, the company made a provision for an outstanding bill of 90,000 for purchase of raw material. Out of such outstanding amount, the company paid - 45,000 in cash on 20th August, 2024. (5) During the year, the company has issued 1,00,000 equity shares of face value of 10 each at premium of 90 each. The fair market value is 60 per share at the time of issue of shares. (6) Plot was sold in March, 2025 for 58,00,000 was acquired by the company in January, 2023 for 50,00,000. (7) The eligible salary and dearness allowance for the pension scheme referred to under section 80CCD is 10,00,000. (8) The company declared interim dividend @10% of share capital being - 5,20,000 in September, 2024. (9) Cost Inflation Index – FY 2022-23: 331; FY 2024-25: 363 Compute total income and tax liability of Tirupati Private Limited as per section 115BAA for the Assessment Year 2025-26 stating reasons for treatment of each item.

Suggested Answer and Working Notes:

Computation of Total Income and Tax Liability of Tirupati Private Ltd. as per section 115BAA for the A.Y.2025-26 Particulars Amount (₹) I Income from house property [Rental income from commercial property] Gross Annual Value¹/Net Annual Value 5,30,000 Less: Deduction under section 24(a) 30% of Net Annual Value 1,59,000 3,71,000 II Profits and gains of business and profession Net profit as per profit and loss account 1,07,00,000 Add: Items debited but to be considered separately or to be disallowed B (ii) Donation paid to Swachh Bharat Kosh 85,000 [Not an expenditure incurred wholly and exclusively for the manufacturing business. Hence, not allowable under section 37] B (iii) Contribution towards pension scheme of employees 50,000 [Contribution towards pension scheme, referred to in section 80CCD, of employees is allowed only to the extent of 14% of salary of the employee in the P.Y. i.e.,1,40,000 being 14% of 10,00,000. Therefore, the excess contribution of 50,000 [i.e.,1,90,000 -1,40,000] is disallowed u/s 36(1)(iva). B (iv) Payment to transport contractor - [As per section 194C(6), no tax is required to be deducted at source since the payment is to a transport contractor not having more than 10 goods carriages at any time during the previous year and he has given a declaration to that effect along with his PAN. Hence, disallowance under section 40(a)(ia) for non-deduction of tax at source is not attracted. Also, since payment is made by account payee cheque, no disallowance under section 40A(3) is attracted]. B (v) Bonus to employees 4,48,000 [Since the payment is made after the due date of filing return of income, disallowance under section 43B is attracted] B (vi) Provision for income-tax (including interest of 70,000 thereon) 4,20,000 [Not allowable as deduction. Disallowance under section 40(a) (ii) is attracted] B (vii) Contribution to a University approved and notified u/s 35(1)(ii) 1,00,000 [No deduction is allowed u/s 115BAA in respect of contribution to a University approved and notified u/s 35(1)(ii)] B (viii) Interest on loan borrowed for investing in shares of ABC Inc. 1,50,000 [Allowability or otherwise of interest expenditure on earning dividend has to be considered separately under the head "Income from Other Sources"] 12,53,000 1,19,53,000 Add: Cash Payment for purchase of raw material deemed as income 45,000 A(4) [Since the provision for outstanding bill for purchase of raw material has been allowed as deduction during the P.Y.2023-24, cash payment in excess of 10,000 against such bill in the P.Y. 2024-25 would be deemed as income of P.Y.2024-25 as per section 40A(3A)] 1,19,98,000 Less: Expenditure to be allowed B (i) & A(1) Depreciation 4,89,000 [Difference between the normal depreciation of 16.75 lakhs as per Income-tax Act, 1961 [See Note below] and depreciation charged to the statement of profit and loss of 11.86 lakhs]. Note - ²Printers and scanners form an integral part of the computer system and they cannot be used without the computer. Thus, they are part of the computer system, they would be eligible for depreciation at the higher rate of 40% applicable to computers including computer software. However, EPABX is not a computer and is, hence, not entitled to higher depreciation @40%³. Accordingly, depreciation of 1,25,000 on EPABX computed @ 25% (40% - 15%) is to be reduced from the depreciation given as per the Income-tax Act, 1961 of 18lakhs. Thus, depreciation as per Income-tax Act, 1961 allowed as deduction would be - 16.75 lakhs. A(2) Additional depreciation on new plant and machinery Nil [Not allowable as deduction under section 115BAA] A(3) Audit Fees relating to P.Y.2023-24 30,000 [₹ 30,000, being 30% of audit fees of 1,00,000 provided for in the books of account of F.Y.2023-24 would have been disallowed due to non-deduction of tax at source. Since tax has been deducted in October, 2024 and paid on 12.12.2024, the amount of 30,000 is deductible while computing business income of P.Y.2024-25]. 5,19,000 1,14,79,000 Less: Items credited to statement of profit and loss, but not includible in business income A (i) Rent received from vacant land 2,55,000 [Chargeable to tax under the head "Income from other sources"] A (ii) Rent received from commercial property owned by the company 5,30,000 [Chargeable to tax under the head "Income from house property"] A (iii) Interest received on income tax refund 48,000 [Chargeable to tax under the head "Income from other sources"] A (iv) Profit on sale of plot 8,00,000 [Chargeable to tax under the head "Capital Gains"] A (v) Dividend from ABC Inc. company 6,00,000 [Dividend received from foreign company is taxable under the head "Income from Other Sources"] 22,33,000 92,46,000 Profits and gains from the business of manufacturing 92,46,000 III Capital Gains Capital gain on sale of plot Sale consideration 58,00,000 Less: Cost of Acquisition [since land is transferred on or after 23.7.2024, indexation benefit will not be to a person other than an individual or a HUF, resident in India] 50,00,000 Long-term capital gain 8,00,000 IV Income from Other Sources Rent received from vacant land 2,55,000 Interest received on income-tax refund 48,000 Excess of issue price of shares over the fair market value of shares is not taxable w.e.f. A.Y. 2025-26 - Dividend from ABC Inc., a foreign company 6,00,000 Less: Interest expenditure of 1,20,000 (₹ 1,50,000 allowed deduction upto 20% of dividend) 4,80,000 7,83,000 Gross Total Income 1,12,00,000 Less: Deductions under Chapter VI-A Deduction under section 80G - Not allowable u/s 115BAA Deduction under section 80M 4,80,000 Deduction in respect of inter-corporate dividend to the extent of 5,20,000, being dividend distributed by it one month prior to the due date specified u/s 139(1) or - 4,80,000 dividend received to the extent includible in the gross total income, whichever is lower Total Income 1,07,20,000 Computation of tax liability Tax on long-term capital gains @ 12.5% 1,00,000 Tax on other income @22% on 99,20,000 21,82,400 22,82,400

Topics: Profits and Gains of Business or Profession

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