M/s Bittu Inc. (a notified Foreign Institutional Investor "FII"), has furnished following details regarding its income for the financial year…

CA Final · Direct Tax Laws and International Taxation · PYQS · September 2025
M/s Bittu Inc. (a notified Foreign Institutional Investor "FII"), has furnished following details regarding its income for the financial year 2024-25: Short Term Capital Gains: Sale proceeds on sale of equity shares of Company 'A' (Sold on 10.02.2025):16,90,000 Cost of acquisition (Purchased on 08.09.2024):6,00,000 STT paid both at the time of purchase and sale Sale proceeds on sale of equity shares of Company 'B' (Sold on 29.12.2024):11,50,000 Cost of acquisition (Purchased on 24.05.2024):5,65,000 (STT not paid on shares of Company 'B') Long Term Capital Gains: Sale proceeds on sale of securities on 13.01.2025:55,00,000 Purchase cost of securities on 18.06.2015:29,00,000 Cost inflation index: Financial year 2015-16: 254, 2024-25: 363 Income on securities: Interest received from an Indian Company on investment in rupee denominated bonds (Issued on 25.06.2020):18,50,000 Dividend income from Indian Companies:2,25,000 Interest on other securities of Indian Companies:8,00,000 Compute the total income and tax liability of M/s Bittu Inc. for the assessment year 2025-26.

Suggested Answer and Working Notes:

Computation of total income of M/s Bittu Inc., a notified FII, for A.Y. 2025-26 Particulars Particulars ₹ Capital Gains Short-term capital gains on sale of STT paid equity shares of Company "A" Sale consideration 16,90,000 Less: Cost of acquisition 6,00,000 10,90,000 Short-term capital gains on sale on STT not paid equity shares of Company “B” Sale consideration 11,50,000 Less: Cost of acquisition 5,65,000 5,85,000 Long-term capital gains on sale of securities Sale consideration 55,00,000 Less: Cost of acquisition [Benefit of indexation is not allowable] 29,00,000 26,00,000 Income from Other Source Interest received from an Indian company on investment in rupee denominated bonds [18,50,000/79.20x100] 23,35,859 Interest on other securities 8,00,000 Dividend from Indian companies 2,25,000 33,60,859 Total Income 76,35,859 Total Income (Rounded off) 76,35,860 Computation of tax liability of M/s Bittu Inc. for A.Y.2025-26 Particulars ₹ Tax @ 20% on interest on securities, dividend and rupee denominated bonds = 20% x 33,60,859 6,72,172 Tax @ 10% on long-term capital gains on sale of securities= 10% x 26,00,000 2,60,000 Note – Alternatively, if it is assumed that the long-term capital gain on sale of securities - 26,00,000 is covered by section 112A, the same will be eligible for exemption of 1,25,000 and the balance is liable to tax @12.5% (date of sale 13.01.2025). Accordingly, tax on long-term capital gains on sale of securities would be - 3,09,375 (12.5% on 24,75,000). Tax @ 20% on short-term capital gains on sale of STT paid equity shares of Company “A” = 20% of 10,90,000 2,18,000 Tax @ 30% on short-term capital gains on sale of STT not paid equity shares of Company “B” = 30% of 5,85,000 1,75,500 13,25,672 Add: Surcharge @ 10% [Since the total income exceeds 50lakhs but does not exceed 1crore]³ 1,32,567 14,58,239 Add: HEC@4% 58,330 Tax liability 15,16,569 Tax liability (rounded off) 15,16,570

Topics: Non-Resident Taxation

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