Compute the total income and tax liability Winter Technologies Inc., a non-resident German company for the A.Y. 2025-26. The following are the…
CA Final · Direct Tax Laws and International Taxation · MTP · January 2026
Compute the total income and tax liability Winter Technologies Inc., a non-resident German company for the A.Y. 2025-26. The following are the details of income earned in India during the year ended on 31.03.2025: (i) Dividend income of 12,50,000 from BlueWave Ltd., an Indian company listed on recognized stock exchange. (ii) 8% debentures of 20,00,000 received from X Ltd., an Indian Company, on October 1, 2024, in consideration of providing technical knowhow (date of payment of interest being March 31 every year). (iii) Dividend of 5,50,000 on Global Depository Receipts of Greenfields Ltd., an Indian company, issued under a scheme of Central Government against the initial issue of shares of the company and purchased by Winter Technologies Inc. in foreign currency through an approved intermediary. (iv) Business Income of 8,00,000 from a unit established at Mumbai. (v) Income by way of royalty (other than referred to in section 44DA) amounting to 10,00,000, from RedTech Ltd., an Indian company, in pursuance of an agreement approved by Central Government. As per DTTA between the two countries, such royalty is taxable @22%.
Suggested Answer and Working Notes:
Computation of total income and tax liability of Winter Technologies Inc., a non-resident German company, for the A.Y. 2025-26: Particulars ₹ Profits and gains from business or profession Business Income from a unit established at Mumbai 8,00,000 Income from other sources ➢ Dividend income from BlueWave Ltd. an Indian company 12,50,000 ➢ Fees for technical services [would be equivalent to the amount of debentures of 20,00,000 received from an Indian company, issued in consideration of providing technical knowhow] 20,00,000 ➢ Interest on Debentures [₹ 20,00,000 x 8% x 6/12] 80,000 ➢ Dividend on Global Depository Receipts (GDRs) of Greenfields Ltd. an Indian company, issued under a scheme of Central Government against the initial issue of Greenfields Ltd. and purchased in foreign currency by Winter Technologies Inc 5,50,000 ➢ Royalty income received from RedTech Ltd. an Indian company in pursuance of an agreement approved by Central Government 10,00,000 Gross Total Income/ Total income 56,80,000 Computation of tax liability Dividend income of 12,50,000, taxable @20% u/s 115A 2,50,000 Dividend on GDRs of 5,50,000, taxable @10% u/s 115AC 55,000 Royalty income of 10,00,000, taxable @20% u/s 115A, since it is in pursuance of an agreement approved by the Central Government 2,00,000 FTS of 20,00,000, taxable @35%, since it is not in pursuance of an agreement approved by the Central Government 7,00,000 Interest on debentures of 80,000, taxable @35%, since debt is incurred in Indian currency, it is not eligible for concessional rate of 20% u/s 115A 28,000 Business income of 8,00,000 [taxable @35%] 2,80,000 15,13,000 Add: Health and education cess@4% 60,520 Tax liability 15,73,520
Topics: Non-Resident Taxation
Related Questions in this Topic
- Answer any two of the following three sub-parts (i), (ii), (iii) on the basis of decided case laws, bringing out the fol...
- Mr. Bhushan, an Indian citizen aged 51 years, left India for the first time on 1 st April 2021 to settle in Country X. ...
- AILES Inc (a foreign company)., a notified Foreign Institutional Investor (FII), derived the following incomes for the f...
- Standalone Multiple Choice Questions.
- Mr. Arjun Mehta (36 years), an Indian citizen, working in India in an MNC got a job opportunity outside India during the...