The net profit of Peacock Ltd. as per its statement of profit and loss for the year ended 31.03.2025 amounted to 27,22,000 after debiting/ crediting…

CA Final · Direct Tax Laws and International Taxation · MTP · January 2026
The net profit of Peacock Ltd. as per its statement of profit and loss for the year ended 31.03.2025 amounted to 27,22,000 after debiting/ crediting following items: Payment of interest on money borrowed from bank for purchase of new Machinery from Australia - 2,00,000. The machinery could not be imported in India due pending approvals from authorities till 31.03.2025.Commission of 1,00,000 paid in the month of February, 2025 on which tax was deducted in February, 2025 itself. Commission of 1,25,000 paid in the month of March, 2025 on which tax was deducted in May, 2025. Tax deducted at source on these payments was deposited to the Government on 28.09.2025.Travelling expenses of 90,000 on a foreign tour of a director for negotiating collaboration with a foreign manufacturer for initiation of new line of business.As part of the restructuring of its debt, the company has converted arrears of interest of 3,00,000 on term loan into a new term loan with a revised repayment schedule. The company has paid - 50,000 towards such funded interest during the year.3,00,000 is debited to statement of profit and loss.On EPABX and mobile phones (exclusively used for business purpose) purchased during the year, depreciation amounting to 18 lakhs was claimed at 40% treating them as computers. 5,00,000, being contribution to S Ltd. (wholly owned subsidiary company) for construction of a school for the benefit of employees of Peacock Ltd.Dividend received from P Ltd. on 10,000 equity shares of 10 each purchased at 100 per share on 10th October, 2017. The rate of dividend declared is 100%, the record date being 10th December, 2024. These shares were sold on 15.3.2025 at 130 per share. Long term capital gain of 3 lakhs is credited in statement of profit and loss. Fair market value of shares as on 31.1.2018 is 110. STT paid both at the time of purchase and sale.Provision for gratuity based on actuarial valuation - 6,00,000 was debited to statement of profit and loss. Actual gratuity paid - 1,50,000 was debited to provision for gratuity account. Other information: Provision for bonus for the year 2023-24 paid on 15.11.202498,000. It is inclusive of payment by bearer cheque of 34,000 to one employee.The company has purchased and put to use another new machinery of 8,00,000 from ABC Ltd., an Indian Company for the purpose of business on 21.03.2025 and calculated depreciation@15% for the full year. Depreciation debited to the statement of profit and loss is calculated on all other assets as per the rates prescribed in the Income-tax Act, 1961. Compute the total income of the company chargeable to tax for the A.Y. 2025-26, ignoring the provisions of section 115JB. Company is not opting for any concessional tax regimes.

Suggested Answer and Working Notes:

Computation of total income of Peacock Ltd. for A.Y.2025-26 Particulars Particulars ₹ Profits & Gains of Business of Profession Net Profit as per Statement of Profit & Loss 27,22,000 Add: Items debited but to be considered separately or to be disallowed Interest on money borrowed for purchase of land 2,00,000 [As per section 36(1)(iii), interest on borrowed capital till the asset is put to use has to be capitalized. Hence, interest on moneys borrowed is not allowable under section 36(1)(iii). Since it is already debited to statement of profit and loss, the same has to be reduced.] Commission paid in February, 2025 Nil [Commission paid in February, 2025 after deduction of tax is allowable as deduction during the P.Y. 2024-25 since TDS has been deposited before the due date of filing return of income. Since commission is already debited to statement of profit and loss, no adjustment is required.] Commission paid in March, 2025 37,500 [30% of commission paid in March 2025 on which TDS was deducted and paid in subsequent year would be disallowed during the P.Y. 2024-25 and would be allowed as deduction in the year in which such tax has been paid. Hence, 30% of commission debited to statement of profit and loss would be added back] Travelling expenses on foreign tour in connection with new line of business 90,000 [Travelling expenses incurred on foreign tour of a director for initiating a new line of business is a capital expenditure. The same is, therefore, not deductible under section 37(1). Since it is already debited to statement of profit and loss, the same has to be reduced.] Interest on term loan converted into new term loan 2,50,000 [Under section 43B, interest on loan due to any scheduled bank, etc. is allowed as deduction, if such interest is actually paid irrespective of the method of accounting followed by the assessee. Conversion of arrear interest into a fresh loan by a bank cannot be considered as actual payment of interest. However, the amount of funded interest (i.e., converted loan) actually paid is allowable as deduction. Hence, out of 3lakhs, only - 50,000, being the funded interest was actually paid which is allowable as deduction while computing business income of P.Y. 2024-25. The balance of 2,50,000 has to be added back.] Excess depreciation provided on EPABX & Mobile phones not allowable as deduction 11,25,000 [EPABX and mobile phones are not computers and therefore, are not entitled to depreciation @40%. It was so held by the Kerala High Court in Federal Bank Ltd. v. ACIT (2011) 332 ITR 319. Therefore, EPABX and mobile phones would be entitled to depreciation of 6,75,000, calculated by applying the rate of 15%, being the general rate applicable to plant and machinery, on the cost of 45,00,000 (₹ 18,00,000 × 100/40). The excess depreciation of 11,25,000 (being - 18,00,000 - 6,75,000), debited to statement of profit and loss, has to be added back.] Contribution to S Ltd. (wholly owned subsidiary company) - [Contribution to a wholly owned subsidiary company for construction of a school for the benefit of its employees is allowable under section 37(1).] Provision for gratuity - 6,00,000 Less: Gratuity paid - 1,50,000 4,50,000 [Under section 40A(7), no deduction is allowed in respect of any provision made for the payment of gratuity to the employees on retirement or termination of employment for any reason. However, gratuity actually paid is admissible as deduction. Therefore, provision for gratuity of 6,00,000 is to be disallowed. Actual gratuity paid - 1,50,000 debited to provision for gratuity account is allowable. Hence, only the net sum of 4,50,000 has to be added back.] Depreciation on new machinery 60,000 22,12,500 [Depreciation on new machinery has been calculated @15% and, consequently,1,20,000 has been debited to statement of profit and loss. Since it was acquired in March 2025 only, 50% of normal depreciation is allowable. The excess depreciation of 60,000 is, hence, disallowed.] 49,34,500 Less: Items credited but to be considered separately and those not charged but to be allowed Long term capital gain on sale of equity shares 3,00,000 [Taxable under the head “Capital gains"] Bonus paid on 15.11.2024 in respect of previous year 2023-24 disallowed last year but allowable in P.Y. 2024-25 64,000 [Provision for bonus for the previous year 2023-24 would have been disallowed under section 43B for non-payment by due date for filing of return of income for assessment year 2024-25. Payment of bonus made after the said date is allowed in the year of actual payment. However, such deduction allowable in the year of payment is subject to the provisions of section 40A(3). Hence, the sum of 34,000, being bonus paid by bearer cheque shall not be allowed as deduction in the year of payment.] Dividend from P Ltd. 1,00,000 4,64,000 [Dividend is taxable under the head "Income from Other Sources"] 44,70,500 II Capital Gains Long term capital gain on sale of equity shares [Taxable @12.5% on sum exceeding - 1,25,000] Sale consideration [10,000 x 130] 13,00,000 Less: Cost of acquisition 11,00,000 2,00,000 Higher of Actual cost of 10lakhs [10,000 x 100] Lower of fair market value as on 31.1.2018 of 11lakhs or sale consideration of 13lakhs III Income from Other Sources Dividend from P Ltd. 1,00,000 [Dividend is taxable under the head "Income from Other Sources"] Total Income 47,70,500

Topics: Profits and Gains of Business or Profession

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