Ms. Ritika aged 30 years, a resident individual, started a business of printing mobile skins and covers in India and abroad. She frequently visits…

CA Final · Direct Tax Laws and International Taxation · RTP · January 2026
Ms. Ritika aged 30 years, a resident individual, started a business of printing mobile skins and covers in India and abroad. She frequently visits Country Z to serve her overseas clients. The following particulars are furnished for the Financial Year 2024-25: 1. Receipts from selling of phone skins and covers: In India -12,45,50,780In Country Z - 15,50,000 2. Expenses incurred in earning the above income: In India -10.20 croresIn Country Z – 9 lakh 3. Rent received from a commercial property situated in Country Z - 65,000 per month. 4. Expenses incurred for earning such rental income in Country Z - 1,50,000. Additional Information: (i) In Country Z, all income are taxed at a flat rate of 25% after deduction of all expenses. (ii) Business Expansion in India: In F.Y. 2024-25, Ms. Ritika expanded her mobile accessories business by opening a large manufacturing unit in Pune.She hired the following new employees for unit of Pune:18 employees on 01.05.2024 having salary of 23,300 each22 employees on 01.06.2024 having salary of 24,500 each15 employees on 01.11.2024 having salary of 24,700 each (Note - All employees participate in recognized provident fund and payment to all employees are made by NEFT. Such expenses are already included in the expenditure given above in relation to business in India) (iii) India does not have any DTAA with Country Z. (iv) Ms. Ritika is paying tax as per the default tax regime u/s 115BAC(1A). You are required to compute the total income and net tax liability of Ms. Ritika chargeable to tax in India for A.Y. 2025-26.

Suggested Answer and Working Notes:

Computation of total income and net tax liability of Ms. Ritika for A.Y. 2025-26 as per the default tax regime under section 115BAC Particulars Particulars ₹ Income from House Property Rent Received in Country Z [₹ 65,000 × 12] 7,80,000 Less: Deduction under section 24(a) @30% 2,34,000 5,46,000 Profit and Gains of Business or Profession Sales in India 12,45,50,780 Less: Expenses 10,20,00,000 2,25,50,780 Sales in Country Z 15,50,000 Less: Expenses 9,00,000 6,50,000 Gross Total Income 2,37,46,780 Less: Deduction u/s 80JJAA is permissible even if paying tax under default tax regime [(₹ 23,300 x 18 x 11) + (₹ 24,500 x 22 x 10)] x 30% [15 employees employed for a period of less than 240 days during the P.Y. 2024-25 not considered as additional employee for deduction u/s 80JJAA for the said previous year] 30,01,020 Total Income 2,07,45,760 Tax on Total Income [1,40,000 + 1,92,45,760 x 30%] 59,13,728 Add: Surcharge @25% since total income exceed 2crores 14,78,432 73,92,160 Less: Marginal Relief (Refer Working Note 1 Below) 1,02,900 72,89,260 Add: Health and Education Cess @4% 2,91,570 75,80,830 Less: Deduction u/s 91 (Refer Working Note 2 below) 2,99,000 Net Tax Liability 72,81,830 Working Notes 1. Computation of Marginal Relief Particulars Amount (₹) (A) Tax on total income - 2,07,45,760 plus surcharge @25% 73,92,160 (B) Tax computed on total income of 2crore plus surcharge @15% 65,43,500 (C) Total Income - 2,07,45,760 -2,00,00,000 7,45,760 (D) Income-tax computed on total income of 2crores plus excess of total income over 2crores 72,89,260 Marginal relief (A) – (D) 1,02,900 Alternative Method (A) Tax on total income - 2,07,45,760 plus surcharge @25% 73,92,160 (B) Tax computed on total income of 2crore plus surcharge @15% 65,43,500 (C) Excess Tax payable (A) – (B) 8,48,660 Marginal Relief [8,48,660 -7,45,760, being the amount of income in excess of 2crores] 1,02,900 2. Computation of Relief u/s 91 Particulars Amount (₹) Average rate of tax in India (₹ 75,80,830/2,07,45,760) x 100 36.54% Average rate of Tax in Country Z 25% Doubly Taxed Income pertaining to Country Z 5,46,000 +6,50,000 = 11,96,000 11,96,000 Deduction u/s 91 = Lower of average rate of tax in India and Country Z x Double Taxed Income = [25% x 11,96,000] 2,99,000

Topics: Double Taxation Relief

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