Ms. Kanika Tondon is a popular Indian pop singer. She has business interest in Country X and Y as well. She is a resident in India for the A.Y.…
CA Final · Direct Tax Laws and International Taxation · RTP · September 2025
Ms. Kanika Tondon is a popular Indian pop singer. She has business interest in Country X and Y as well. She is a resident in India for the A.Y. 2025-26. The details of income earned by Ms. Kanika Tondon from India as well as Country X and Country Y with which India does not have any DTAA, during the P.Y. 2024-25 are as under: Type of Income India X Y (₹ in crores) Income from house property (Computed) 4.3 (1.3) Business/Professional income: Singing profession 9 - 2 From being the owner of cricket team Delhi Super Players 5.5 - - Other business 7.2 2.9 Share income from partnership firm (not evidenced by an instrument in writing) 4.8 - Agricultural income 1.5 - 1.2 Ms. Kanika has deposited - 1.5 lakhs in PPF and paid Life Insurance premium of 1 lakh. In Country X, share income is not exempt and loss from house property is not eligible for being set off against other income. In Country Y, agricultural income is chargeable to income-tax. In Country X, Ms. Kanika has paid income-tax of 2.16 crores and in Country Y - 2.44 crores on the total income earned in those countries. Compute the net tax liability of Ms. Kanika for the A.Y.2025-26, assuming that she is paying tax under default tax regime under section 115BAC.
Suggested Answer and Working Notes:
Computation of net tax liability of Ms. Kanika Tondon for A.Y.2025-26 Particulars Particulars ₹ I Income from house property Income from house property in India 4,30,00,000 Less: Loss from house property in Country X 1,30,00,000 3,00,00,000 II Profits and gains of business or profession Business/ Professional income in India 14,50,00,000 - From singing profession 9,00,00,000 - From being the owner of cricket team Delhi Super Players 5,50,00,000 Business/ Professional income in Country X - Other business 7,20,00,000 - Share income from firm 4,80,00,000 12,00,00,000 Business/Professional income in Country Y - Singing profession 2,00,00,000 - Other business 2,90,00,000 4,90,00,000 31,40,00,000 III Income from Other Sources Agricultural income from India [Exempt u/s 10(1)] - Agricultural income from Country Y 1,20,00,000 1,20,00,000 Gross Total Income 35,60,00,000 Less: Deductions under Chapter VI-A [Not allowable since Ms. Kanika is paying tax under default tax regime] Nil Total Income 35,60,00,000 Computation of tax liability: Step 1: Tax on 37,10,00,000, being non-agricultural income and agricultural income [30% x 36,95,00,000 +1,40,000] 11,09,90,000 Step 2: Tax on 1,53,00,000, being agricultural income and basic exemption limit of 3,00,000 [30% x 1,38,00,000 +1,40,000] 42,80,000 Step 3: Step 1 - Step 2 10,67,10,000 Add: Surcharge@25% (since her total income exceeds 2crore) 2,66,77,500 13,33,87,500 Add: HEC @4% 53,35,500 Tax liability 13,87,23,000 Less: Deduction under section 91 [See Working Notes 1 & 2 below] 4,30,29,870 Net Tax liability (rounded off) 9,56,93,130 Working Note 1: Computation of deduction under section 91 Particulars ₹ ₹ Average rate of tax in India [13,87,23,000 x 100/35,60,00,000] 38.967% Average rate of tax in Country X [2,16,00,000 x 100/12,00,00,000] 18% Average rate of tax in Country Y [2,44,00,000 x 100/6,10,00,000] 40% I Deduction under section 91 in respect of doubly taxed income in India and Country X Doubly taxed income: Country X (i.e.,7.2 crores, being business income (+) ₹ 4.8 crores, being taxable share income from firm (-) ₹ 1.3 crores, loss from house property) 10,70,00,000 Lower of Indian rate of tax of 38.967% and rate of tax in Country X of 18% 18% Deduction u/s 91 = 18% x 10.70 crores 1,92,60,000 II Deduction under section 91 in respect of doubly taxed income in India and Country Y Doubly taxed income: Country Y (i.e.,2 crores, being professional income (+) ₹ 2.9 crores, being business income (+) ₹ 1.2 crores, being taxable agricultural income) 6,10,00,000 Lower of Indian rate of tax of 38.967% and rate of tax in Country X of 40% 38.967% Deduction u/s 91 = 38.967% x 6.10 crores 2,37,69,870 Deduction under section 91 4,30,29,870
Topics: Double Taxation Relief
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