Mr. Deewan, a resident individual in India aged 46 years, received the following incomes during the FY 25-26: Computed Income from house property in…

CA Final · Direct Tax Laws and International Taxation · RTP · November 2026
Mr. Deewan, a resident individual in India aged 46 years, received the following incomes during the FY 25-26: Computed Income from house property in Delhi: ₹ 6,20,000. Incomes from the Country X and Y with whom India has Signed DTAA: (i) Royalty from Country X: ₹ 8,60,000 (Rate of tax in Country X is 10% and tax deducted at source was ₹ 86,000). As per DTAA with Country X, the royalty is only taxable in the source state. (ii) Interest on securities from Country Y: YSD 12,000 (Interest became due on 31st December 2025) and tax deducted (on 14th February 2026) YSD 1,200 (Rate of tax 10%). As per DTAA with Country Y, interest can be taxed in both the contracting states and tax credit will be available in resident state in respect of tax payable in source state. Incomes from the Country R with whom India has not signed any DTAA: - Agricultural income in Country R: ₹ 2,40,000 (Taxable in Country R) - Loss from house property (computed) in Country R - ₹ 1,60,000 which is not eligible for set-off against any other income in Country R. Income Tax Rate in Country R is 20%. Income received in India in Foreign convertible currency before due date of filing of Income Tax Return. TTBR rate of 1 YSD on various dates: 31.03.2025 - ₹ 83; 30.11.2025 - ₹ 80; 31.12.2025 - ₹ 82 31.01.2026 - ₹ 84; 14.02.2026 - ₹ 82; 31.03.2026 - ₹ 81 Compute the total income and net tax liability of Mr. Deewan for the A.Y. 2026-27, assuming that he has shifted out from the default tax regime. As per DTAA with Country X and Y, Mr. Deewan is resident of India.

Suggested Answer and Working Notes:

18. Computation of total income of Mr. Deewan for A.Y.2026-27 under normal provisions of the Income-tax Act Income from House Property Income from House property in Delhi (Computed) 6,20,000 Less: Loss from House Property in Country R (Computed) 1,60,000 4,60,000 Profits and gains of business or profession Royalty from Country X (Taxable in the source state only, hence not taxable in India) - Income from other Sources Interest on securities from Country Y (YSD 12,000 x 80, being the TTBR as on 30.11.2025, being the last day of the month immediately preceding the month in which income is due) 9,60,000 Agricultural income in Country R 2,40,000 12,00,000 Gross Total Income 16,60,000 Computation of Net tax liability Tax on total income (30% of 6,60,000 plus ₹ 1,12,500) 3,10,500 Add: Health and Education Cess @4% 12,420 Tax liability 3,22,920 Less: Deduction u/s 91 with respect to income from Country R with which India has no DTAA (See Working Note 1 Below) 15,560 Working Note 1: Deduction with respect to Country R with which India has no DTAA Indian Average Rate of tax = ₹ 3,22,920/ 16,60,000 x 100 19.45% Average rate of tax in Country R 20% Doubly taxed income pertaining to Country R Agricultural income 2,40,000 Less: Loss from house property 1,60,000 80,000 Deduction u/s 91 on ₹ 80,000 @19.45%, being lower average rate of tax in India (19.45%) and tax rate in Country R (20%) 15,560 Working Note 2: Deduction with respect to Country Y with which India has DTAA shall be lower of Tax paid in India in respect of interest on securities [9,60,000 x 19.45%] 1,86,720 Tax paid in Country Y in respect of royalty [YSD 1,200 x 84, being the TTBR on 31.1.2026] 100,800 Foreign tax credit = Lower of tax paid in India and Country Y 1,00,800

Topics: Double Taxation Relief

Open in Interactive Practice Hub · Full Practice Hub · Chapter Weightage · More in this subject

Related Questions in this Topic