(i) "Helping Hands Foundation", a charitable trust registered under section 12AB of the Income-tax Act, got merged with another entity on 01st April…

As per section 115TD, the accreted income of "Helping Hands Foundation", a charitable trust, registered under section 12AA which merged with an entity not entitled for registration under section 12AB or approval under section 10(23C), would be chargeable to tax at maximum marginal rate @34.944% [30% plus surcharge @12% plus cess@4%]. Computation of accreted income and tax liability in the hands of the trust arising as a result of merger with the "not eligible" entity for A.Y. 2025-26 Particulars Amount (₹) Aggregate FMV of total assets as on 1.4.2024, being the specified date (date of merger) [See Working Note 1] 1,49,50,000 Less: Total liability computed in accordance with the prescribed method of valuation [See Working Note 2] 104,00,000 Accreted Income 45,50,000 Tax Liability @34.944% of 45,50,000 15,89,952 Working Notes: (1) Aggregate fair market value of total assets on the date of merger - Land, being an immovable property [The fair market value of land would be higher of 19lakhs i.e., price that the land would ordinarily fetch if sold in the open market and 24lakhs, being stamp duty value as on the specified date] 24,00,000 - Quoted equity shares in FGT Ltd. [75,000 x 90 per share] [90per share, being the average of the lowest (85) and highest price (95) of such shares on the date of merger] 67,50,000 - 55,000 preference shares of KEY's Ltd. [The fair market value which it would fetch if sold in the open market on the date of merger i.e., FMV on 1.4.2024] 58,00,000 1,49,50,000 (2) Total liability - Outside liabilities 83,00,000 - Corpus Fund of 19lakhs [not includible] - - Provision for taxation 11lakhs [not includible] - - Liabilities in respect of payment of various utility bills [since this liability is an ascertained liability] 21,00,000 1,04,00,000