M/s S. International (a company registered in Australia), during the financial year 2024-25 was engaged in the business of operating passenger…

CA Final · Direct Tax Laws and International Taxation · PYQS · September 2025
M/s S. International (a company registered in Australia), during the financial year 2024-25 was engaged in the business of operating passenger cruise ships in India. The cruise ships owned by M/s S. International, operates between Mumbai & Lakshadweep and Mumbai & Goa ports. M/s S. International fulfills all the conditions prescribed under the presumptive taxation provision applicable to nature of the income from the passenger cruise ships operated by it in India. In the above facts, the amount of profit chargeable to tax in the case of M/s S. International for Assessment Year 2025-26 shall be
(A) 7.5% of the aggregate of the amount received or receivable or deemed to be received or receivable on account of carriage of passengers, directly or in-directly.
(B) 20% of the aggregate of the amount paid or payable to M/s S. International (Directly or In-directly) and the amount received or deemed to be received by M/s S. International (Directly or In-directly), on account of carriage of passengers.
(C) 5% of the aggregate of the amount received or receivable or deemed to be received or receivable on account of carriage of passengers, directly or in-directly.
(D) 10% of the aggregate of the amount received or receivable or deemed to be received or receivable on account of carriage of passengers, directly or in-directly.

Suggested Answer and Working Notes:

Correct Answer: Option (B)

20% of the aggregate of the amount paid or payable to M/s S. International (Directly or In-directly) and the amount received or deemed to be received by M/s S. International (Directly or In-directly), on account of carriage of passengers.

Topics: Double Taxation Relief, Profits and Gains of Business or Profession, Non-Resident Taxation

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