Blessings Pharmaceuticals Private Limited is an Indian Company, engaged in the business of manufacturing and providing access to affordable and…

CA Final · Direct Tax Laws and International Taxation · MTP · May 2026
Blessings Pharmaceuticals Private Limited is an Indian Company, engaged in the business of manufacturing and providing access to affordable and innovative medicines and healthcare solutions. The company is incorporated in the year 2009. The company shows a Net Profit of 95 lakhs as per the Statement of Profit and Loss for the year ended March 31, 2026. Net Profit has been arrived at after debiting and crediting the following items: (1) Depreciation as per the Companies Act, 2013 -11.90 lakhs. (2) The amount of employee benefits includes a sum of 13,00,000 in respect of bonus payable to employees. In the previous year 2025-26, the company and its employee's union had a dispute over payment of bonus. In order to avoid late payment of bonus, the company formed a trust and transferred the amount of bonus payable to employees to the said trust. The dispute was settled in the month of August, 2026 and the trust paid the amount of bonus to the employees on 31st August, 2026. (3) An amount paid by the company as regularization fee for violating a law (as prescribed by Medical Council of India) of manufacturing medicines, 9.50 lakhs. (4) An amount of 45,000 was paid as late fees to Government for company's failure in performance of a contract within the stipulated time. There was a delay of 5 months and according to the agreement, the company had to pay late fees of 9,000 per month to the Government. (5) The company earned a profit of 7.50 lakhs on sale of plot of land on 25.08.2025 to Sita Private Ltd., a domestic Company, the entire shares of which are held by the assessee company. The plot was acquired by Blessings Pharmaceuticals Pvt. Ltd. on 20.12.2023. This profit is included in the income of the assessee company. (6) The company earned a profit of 4.50 lakhs on sale of 2,500 shares of M/s Satya Ltd., a listed Indian company. These shares were sold on 08.11.2025 for 280 per share. The highest trading price of Satya Ltd. quoted on the stock exchange as on 31.01.2018 was 175 per share and the Lowest Trading price quoted on the stock exchange was 165 per share. The said shares were acquired for 100 per share on 11.07.2016. STT paid both at the time of purchase and sale of shares. (7) Company debited an interest of 7.50 lakhs which the company remitted as interest to a company incorporated in USA on a loan taken 3 years ago. Tax under section 195 from such interest has been deducted in March 2026, but deposited by the company on 14th July, 2026. (8) The company has contributed - 65,000 to an electoral trust by account payee cheque. Following Additional information is provided by the company for P.Y 2025-26: The depreciation charged in the Statement of Profit and Loss of 11.90 lakhs include the depreciation calculated on following assets: (i) It includes an amount of depreciation of 95,000 in respect of fire fighting equipments installed in the office premises and factories of the assessee. During the year, there was no incidence of fire and hence, the equipments were not used. Amount of depreciation on such equipment as per Income-tax Rules, 1962 is also same. (ii) A new machinery which was installed and put to use on 14.05.2025 valuing 75 lakhs. (iii) A machinery which was sold to a domestic company in 2016 at its WDV for 35 lakhs was re-acquired on July 5, 2025 for 65 lakhs. There is no other fixed asset included by the company's accountant for calculation of depreciation except these three assets mentioned above. You are required to compute total income of the company as per Income-tax Act, 1961 for the Assessment Year 2026-27 indicating reasons for treatment of each item, assuming that the company has not opted for special provisions under section 115BAA or 115BAB.

Suggested Answer and Working Notes:

Computation of Total Income of Blessings Pharmaceutical Pvt. Ltd. for the A.Y. 2026-27 Particulars Amount (in ₹) Profits and gains of business or profession Net profit as per statement of profit and loss 95,00,000 Add: Items debited but to be considered separately or to be disallowed (1) Depreciation as per Companies Act, 2013 11,90,000 (2) Bonus transferred to the trust for making payment to the employees after settlement of the dispute [The bonus would be allowable as deduction u/s 36(1)(ii), even though the amount of bonus payable was initially remitted to the trust created for the purpose of avoiding late payment of bonus, since the actual payment of bonus made to the employees is 31st August, 2026 i.e., on or before due date of filing return of income. Since the same has been already debited to the statement of profit and loss, no further adjustment is required] Nil (3) Regularization fee for violating a law [Regularization fee paid for violating a law as prescribed by Medical Council of India is a payment to compound an offence. Such expenditure is considered to be the expenses prohibited by the law. Hence, it does not qualify for deduction u/s 37. As the same has been debited to the statement of profit and loss, it has to be added back] 9,50,000 (4) Late fees to Government for failure in performance of a contract [Late fees of 45,000 paid for non-fulfilment of a contract within the stipulated time is not for the breach of law but was paid for breach of contractual obligations and therefore, is an allowable expense. Since it is already debited in statement of profit and loss, no further adjustment is required] Nil (7) Payment of Interest to a company incorporated in USA [Since the tax has been deducted in March, 2026 and deposited by the company on 14.7.2026 i.e., on or before due date of filing return of income, no disallowance would be attracted under section 40(a)(i). Since the interest has been already debited to the statement of profit and loss, no further adjustment is required] Nil (8) Contribution to electoral trust [Contribution to electoral trust is not allowable as deduction while computing business income of the company. Since the contribution has been debited to statement of profit and loss, the same has to be added back while computing business income] 65,000 22,05,000 1,17,05,000 Less: Items credited but not taxable or chargeable to tax under another head (5) Profit on sale of plot of land to 100% subsidiary [Capital Gain arising on sale of plot of land is taxable under the head "Capital Gains". Since the profit on sale of plot of land has been credited to the statement of profit and loss, the same has to be deducted while computing business income] 7,50,000 (6) Profit on sale of shares of M/s Satya Ltd. [Capital Gain arising on sale of shares of M/s Satyal Ltd. is taxable under the head "Capital Gains". Since the profit on sale of shares has been credited to the statement of profit and loss, the same has to be deducted while computing business income] 4,50,000 12,00,000 1,05,05,000 Less: Depreciation as per Income-tax Act, 1961 Normal depreciation - On fire-fighting equipments [Eligible for depreciation even though such equipments were not used during the previous year.] 95,000 - On new machinery [₹ 75,00,000 x 15% since it is put to use for more than 180 days] 11,25,000 - On machinery sold and reacquired [15% of actual cost of 35,00,000, being lower of WDV at the time of sale (i.e.,35 lakhs) or price paid for re-acquisition (i.e.,65 lakhs) 5,25,000 Additional depreciation - On new machinery [₹ 75,00,000 x 20%] 15,00,000 32,45,000 72,60,000 Capital Gains Profit on sale of plot of land to 100% subsidiary [Short-term capital gains arise on sale of plot of land held for less than 24 months. However, in this case, since the transfer is to a 100% subsidiary company and the subsidiary company is an Indian company, the same would not constitute a transfer for levy of capital gains tax] Nil Long term capital gain on sale of shares of M/s. Satya Ltd. [Since shares were held for more than 12 months] [Full value of consideration (2,500 x 280)] 7,00,000 Less: Cost of acquisition - Higher of (i) and (ii) 4,37,500 (i) Actual cost of acquisition (2,500 x 100) ₹ 2,50,000 (ii) ₹ 4,37,500, being lower of fair market value as on 31.1.2018 (i.e.,4,37,500, being 2,500 x 175) and sale consideration (i.e.7,00,000) 2,62,500 Gross Total Income 75,22,500 Less: Deduction under Chapter VI-A 65,000 Under section 80GGB [Contribution by a company to an electoral trust is allowable as deduction, since payment is made otherwise than by cash] Total Income 74,57,500

Topics: Profits and Gains of Business or Profession

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