Mr. Shivansh purchased 11,000 equity shares of 10 each of M/s ABC Ltd. on 08.03.2007 at a premium of 40 per share. On 07.10.2024, the Company…

CA Final · Direct Tax Laws and International Taxation · PYQS · September 2025
Mr. Shivansh purchased 11,000 equity shares of 10 each of M/s ABC Ltd. on 08.03.2007 at a premium of 40 per share. On 07.10.2024, the Company buy-backs 1,000 equity shares held by Shivansh at a price of 550 per share. M/s ABC Ltd. distributed its assets to shareholders on its liquidation on 15.11.2024. Shivansh received 100 per share in cash and one plot of land in consideration of remaining 10,000 shares. The book value and fair market value of such land on 15.11.2024 was 45 lakhs and 60 lakhs respectively. On this date, M/s ABC Ltd. has equity share capital of 10,00,000 (1,00,000 equity shares of 10 each) and accumulated profits of 80,00,000. Cost Inflation Index: 2024-25: 363, 2006-07: 122 Compute income chargeable in respect of following in the hands of Mr. Shivansh assuming he has not opted tax regime u/s 115BAC for the A.Y. 2025-26: (1) On buyback of 1,000 equity shares; and (2) Capital Gains chargeable on liquidation.

Suggested Answer and Working Notes:

Computation of income chargeable in the hands of Mr. Shivansh for A.Y. 2025-26 Amount (₹) (1) On buyback of 1,000 equity shares by M/s ABC Ltd. Capital Gains Full Value of consideration Nil Less: Cost of Acquisition [1000 x 50] 50,000 Long-term capital loss [can be set off against long term capital gain on liquidation of company] 50,000 Income from Other Sources Dividend [1,000 x 550] 5,50,000 The sum paid by M/s ABC Ltd., a domestic company for purchase of its own shares would be treated as dividend and taxable under the head "Income from Other Sources" in the hands of Mr. Shivansh. No deduction for expenses would be available against such dividend income (2) Capital gains chargeable on liquidation Capital Gains Full value of the consideration 62,00,000 Cash (10,000 shares x 100 per share) 10,00,000 Market value of land on the date of distribution 60,00,000 70,00,000 Less: Deemed Dividend [8lakhs (80lakhs/1 lakhs x 10,000), being the share of Mr. Shivansh in accumulated profits of 80lakhs would be deemed as dividend] 8,00,000 Less: Cost of acquisition [10,000 × ₹ 50 (₹ 10+40)] 5,00,000 Long-term capital gain 57,00,000

Topics: Capital Gains

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