Mr. Rohan Mehta is a property dealer and also engaged in the business of constructing apartments. A search under section 132 in the business premise…
CA Final · Direct Tax Laws and International Taxation · RTP · January 2026
Mr. Rohan Mehta is a property dealer and also engaged in the business of constructing apartments. A search under section 132 in the business premise of Mr. Rohan was conducted on 10th December 2024. The last of the authorisations was executed on 18th December 2024. The following facts were discovered during the search proceedings – Cryptocurrency of 50 lakhs acquired in the F.Y. 2021-22 andJewellery worth 30 lakhs acquired in the F.Y. 2023-24. Out of this, Rohan could explain source of only 20 lakhs invested in crypto currency and jewellery worth 10 lakhs purchased via NEFT payment. Further, books of account revealed an unexplained expenditure of 15 lakhs incurred during the F.Y. 2022-23 towards foreign travel of family members. No proper source was explained. Loose papers indicated receipt of 40 lakhs in cash for sale of flats during the F.Y. 2020-21. This amount was not recorded in the books of account. It has come to the notice of the Assessing Officer that the assessment for A.Y. 2023-24 was pending under section 143(3) on the date of initiation of the search. The Assessing Officer issued a notice under section 158BC for furnishing a return within 60 days. However, Mr. Rohan Mehta furnished the return after the expiry of 60 days. The Assessing Officer, after considering evidence, determined total income of 1.05 crore and proceeded to levy tax at the rate applicable along with surcharge and cess. He also levied interest @2% of tax on undisclosed income for every month or part of the month for the period after the expiry of 60 days and ending on the date of completion of assessment under section 158BC. On 12.3.2025, Mr. Jeevan and Mr. Shivam purchased an apartment from Mr. Rohan Mehta for 70 lakhs (35 lakhs each). The stamp duty value of the apartment is 48 lakhs. The consideration amount includes 2 lakhs towards car parking and - 50,000 towards maintenance fees. On 20.3.2025, ABC Pvt. Ltd. bought back 50,000 shares including 500 shares from Mr. Jeevan for 1250 per share. Mr. Jeevan acquired these shares for 200 per share in the year 2018. From the information given above, choose the most appropriate answer of MCQs 1 to 5:
Suggested Answer and Working Notes:
Correct Answer: Option (D)
Yes, tax is deductible @1% on consideration payable (including car parking and maintenance fees) by Mr. Jeevan and Mr. Shivam
Topics: Transfer Pricing, Double Taxation Relief, Non-Resident Taxation
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