M/s RST Ltd., a company resident in India, engaged in the manufacturing of leather products. The Statement of Profit & Loss for the year ended…
CA Final · Direct Tax Laws and International Taxation · PYQS · September 2025
M/s RST Ltd., a company resident in India, engaged in the manufacturing of leather products. The Statement of Profit & Loss for the year ended 31st March, 2025 shows a net profit of 97,38,000 after debiting or crediting the following items: (i) Foreign travel expenditure of 12,00,000 regarding three directors for a collaboration agreement with a foreign company for setting up a new plant in London for manufacturing of plastic products. The negotiation could not succeed and project was abandoned. (ii) Goods purchased of 4 lakhs from M/s Shiv Traders (a micro enterprise) were delivered on 16.03.2025. M/s RST Ltd raised the quality issues on 01.04.2025, which were resolved by M/s. Shiv Traders on 05.04.2025. M/s RST Ltd paid the above amount on 29.04.2025. Payment terms agreed was 48 days from date of delivery as per written contract. (iii) Security deposit of 6,50,000 was paid to MNO Ltd. on 01.05.2024 for hiring a building on rent for business purpose. Due to unforeseen circumstances, RST Ltd. vacated the building which resulted in a dispute. To end the dispute, RST Ltd. agreed not to claim the security deposit and claimed the amount as deduction. (iv) Profit of 6,25,000 earned from hedging contract entered into for meeting out loss in foreign currency payments regarding an imported printing machinery valued at 110 lakhs. The machinery was installed and put to use on 05.01.2025. (v) Depreciation of 13,00,000 under the Companies Act, 2013, has been charged. (vi) One plot of land was sold on 28-08-2024 at a profit of 15,00,000 to M/s James Inc., Russia (a wholly owned subsidiary company). (vii) Provision of 9,00,000 has been made for gratuity based on actuarial valuations. The gratuity actually paid of 5,80,000 to retired employees during the financial year was debited to Gratuity Provision account. The Company furnished following additional information: (i) The plot of land sold to M/s James Inc. was purchased at a cost of 32,00,000 on 22.03.2014 and value assessed by the stamp valuation authority was - 60,00,000. (Cost Inflation Index: FY 2013-14: 220, 2024-25:363) (ii) The Company employed following 305 additional workers during the F.Y. 2024-25: No. of workers Date from which employed Regular/Casual Wages/month (₹) 82 01-07-2024 Regular 25,200 96 01-08-2024 Casual 24,800 55 01-09-2024 Regular 25,000 72 07-11-2024 Regular 24,300 The regular employees participate in recognized provident fund while the casual employees do not participate. Additional wages were paid through account payee cheque. (iii) The Company purchased - 7,500 equity shares of M/s PQR Pvt. Ltd. at 40 per share on 05.09.2024. The fair market value per share on such date was 95. (iv) Depreciation on fixed assets as per the Income-tax Rules, 1962 excluding depreciation on imported printing machine is 12,60,000. Compute the Total Income of M/s RST Ltd. for the A.Y. 2025-26. Ignore MAT and the provisions of section 115BAA.
Suggested Answer and Working Notes:
Computation of Total Income of M/S RST Ltd. for the A.Y. 2025-26 Particulars Amount (in ₹) I. Profits and gains of business or profession Net profit as per the Statement of profit and loss 97,38,000 Add: Items debited but to be considered separately or to be disallowed (i) Expenses on foreign travel of three directors for a collaboration agreement which failed to materialize [Where expenditure is incurred for a project not related to the existing business and the project was abandoned without creating a new asset, the expenses are capital in nature¹. Manufacturing plastic products is not related to the existing business of manufacturing leather products. Since the same has been debited to the statement of profit and loss, the same has to be added back while computing business income.] 12,00,000 (ii) Sum payable for purchase of goods from M/s Shiv Traders, a micro enterprise [Since payment was made to a micro enterprise on 29.4.2025 i.e., within 45 days from date of delivery, deduction for purchase of goods is allowed in the P.Y. 2024-25. Since the same has been debited to the statement of profit and loss, no adjustment is required to be made] Nil (iii) Forgoing of security deposit to settle a dispute [The character of the security deposit is of capital nature and remained so though it is decided to forgo it. It cannot be treated as revenue expenditure merely because it was paid in the course of dispute.² Since it has been debited to the statement of profit and loss, the same has to be added back while computing business income] 6,50,000 (v) Depreciation as per the Companies Act, 2013 13,00,000 (vii) Provision for gratuity [Provision of 9 lakhs for gratuity based on actuarial valuation is not allowable as deduction. However, actual gratuity of 5.80 lakhs paid is allowable as deduction. Hence, the difference has to be added back to income. [9lakhs (-) ₹ 5.80 lakhs] 3,20,000 34,70,000 1,32,08,000 Less: Items credited but not taxable or chargeable to tax under another head (iv) Profit from hedging contract [The profit from hedging contract entered into for meeting loss in foreign currency payments towards imported machinery has to be adjusted against the cost of plant and machinery. Since it has been credited to the statement of profit and loss, the same has to be reduced while computing business income] 6,25,000 (vi) Profit on sale of plot of land [Profit on sale of plot of land taxable or otherwise under the head "Capital Gains". Since this amount has been credited to the statement of profit and loss, the same has to be deducted for computing business income]. 15,00,000 21,25,000 1,10,83,000 Less: Depreciation as per the Income-tax Rules Depreciation of fixed assets other than imported machine 12,60,000 Depreciation on imported printing machine [1,03,75,000 (110lakhs -6,25,000) x 15% x 50%, since machinery is put to use for less than 180 days] 7,78,125 Additional depreciation on imported printing machine [₹ 1,03,75,000 x 20% x 50%] 10,37,500 30,75,625 80,07,375 II. Capital Gains Long term capital gain on sale of plot of land As the sale is made to wholly owned subsidiary being a foreign company the transaction would not be tax-free. It would be regarded as 'transfer' and the capital gain is liable to tax. Actual sale consideration [32lakhs +15 lakhs] 47,00,000 Valuation as per stamp valuation authority 60,00,000 Full value of consideration (Since the stamp duty value exceeds 110% of the actual sale consideration, the stamp duty value shall be taken to be the full value of consideration as per section 50C) 60,00,000 Less: Cost of acquisition [No indexation benefits allowable if transfer takes place on or after 23.7.2024] 32,00,000 Long term capital gain [Since plot of land is held for more than 24 months] 28,00,000 III. Income from Other Sources Acquisition of equity shares for inadequate consideration [Since the difference between fair market value of shares i.e.,7,12,500 (7500 x 95) and consideration i.e.,3,00,000 (7500 x 40) exceeds - 50,000, the difference would be taxable under section 56(2)(x)] 4,12,500 Gross Total Income 1,12,19,875 Less: Deduction under Chapter VI-A Deduction under section 80JJAA [30% of additional employee cost of the employees having emoluments of not exceeding - 25,000 employed for 150 days or more, in case of leather industry and participate in recognized provident fund is allowed as deduction. Accordingly, in the present case, 55 regular employees employed on 1.9.2024 would be considered for deduction] [₹ 25,000 x 55 x 7 months] x 30% 28,87,500 Total Income 83,32,375 Total Income (rounded off) 83,32,380
Topics: Profits and Gains of Business or Profession
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