Sheetal Industries Ltd. engaged in production and marketing of diversified products was incorporated in the year 2005. The net profit of Sheetal…

CA Final · Direct Tax Laws and International Taxation · MTP · November 2026
Sheetal Industries Ltd. engaged in production and marketing of diversified products was incorporated in the year 2005. The net profit of Sheetal Industries Ltd. as per its Statement of Profit and Loss for the year ended 31.03.2026 amounted to of ₹ 72,00,000 after considering the following items: A: Items debited to the Statement of Profit and Loss: Depreciation as per the Companies Act, 2013: ₹ 24,00,000 Interest amounting to ₹ 60,000 for short payment of advance tax paid as per section 234B relating to the assessment year 2026-27. Interest and borrowing costs amounting to ₹ 9,50,000 and ₹ 7,00,000 though not meeting the criteria for recognition as a component of cost, included in cost of opening and closing inventory, respectively. Expenditure of ₹ 41,000 paid in cash comprising of ₹ 22,000 directly paid to producer of dairy farming products and ₹ 19,000 paid towards printing and stationery items to a trader. ₹ 3,50,000 paid to a contractor for carrying out repair work at factory premises. Tax was not deducted at source on this payment. ₹ 35,000 towards expenditure for earning income from transfer of carbon credits. Contribution to electoral trust: ₹ 3,00,000 paid by way of cheque. Expenditure towards advertising charges in a brochure of a political party registered under section 29A of Representation of People Act, 1951: ₹ 40,000 paid by way of cheque. Interest on term loan obtained from Cooperative Bank not paid before the due date of filing of return of income ₹ 2,60,000 Actual contribution to the pension scheme of employees: ₹ 1,90,000 B: Items credited to the Statement of Profit and Loss: Unrealised rent of ₹ 3,80,000 pertaining to financial year 2021-22 & 2022-23 recovered during the year in respect of a commercial property owned by the company, which was sold by the company on 23.03.2025. Dividends from a specified foreign company ₹ 1,60,000 Profit of ₹ 3,00,000 received from hedging contract entered into for meeting out loss in foreign currency payments towards an imported printing machinery (used in factory premises) valued at ₹ 95 lakhs, installed on 15 th December, 2025 and put to use from that date. Interest from banks on fixed deposits (net of TDS) at 10%: ₹ 1,35,000. Additional Information: Depreciation as per Income-tax Rules, 1962: ₹ 28,00,000 exclusive of depreciation on the imported printing machine referred to in item B (iii) Expenditure pertaining to previous financial year allowed on due basis, but paid in current financial year in cash on 18.01.2026: ₹ 35,000 Audit fee for the previous year 2024-25: ₹ 75,000. TDS deducted but not paid in the relevant previous year. However, TDS was paid on 31.12.2025. Income from transfer of Carbon Credits amounting to ₹ 4,00,000 included in Net Profit (before tax). The eligible salary and dearness allowance for the pension scheme referred to under section 80CCD is ₹ 10,00,000. Compute the total income of Sheetal Industries Ltd. for assessment year 2026-27 as per the provisions of the Income-tax Act, 1961 ignoring the provisions of section 115JB. Give brief reasons for the treatment given to each of the items considered in computation of income of the company. Company is not opting for any concessional tax regimes.

Suggested Answer and Working Notes:

1. (a) Computation of Total Income of Sheetal Industries Ltd. for the A.Y. 2026-27 Particulars Amount (₹) I Income from house property Unrealised rent [Taxable under section 25A, even if Sheetal Industries Ltd. is no longer the owner of commercial property] 3,80,000 Less: 30% of above 1,14,000 2,66,000 II Profits and gains of business and profession Net profit as per the statement of profit and loss 72,00,000 Add: Items debited but to be considered separately or to be disallowed (i) Depreciation as per the Companies Act, 2013 24,00,000 (ii) Interest under section 234B for short payment of advance tax [Any interest payable for default committed by assessee for discharging his statutory obligations under the Income-tax Act, 1961 which is calculated with reference to the tax on income is not allowable as deduction under section 40(a)(ii). Since the same has been debited to statement of profit and loss, it has to be added back]¹ 60,000 (iii) Interest and borrowing cost included in Opening and Closing inventory. [As per ICDS II, Interest and borrowing cost which does not meet the criteria for recognition as a component of the cost, cannot be included in the cost of inventory. Since the same have been included in the opening and closing inventory, the difference between ₹ 9,50,000, being interest included in opening inventory (-) ₹ 7,00,000 being interest included in closing inventory, has to be added back] 2,50,000 (iv) Cash payment in excess of ₹ 10,000 [Disallowance u/s 40A(3) is attracted in respect of expenditure, for which payment exceeding ₹ 10,000 in a day has been made in cash. Since expenditure of ₹ 19,000 towards printing and stationery items is debited to the statement of profit and loss, the same has to be added back. However, payment of ₹ 22,000 to producer for dairy farming products is not disallowed since it is covered under the exceptions specified in Rule 6DD] 19,000 (v) Repair work paid to contractor without deduction of tax at source [Disallowance of 30% of the amount of ₹ 3,50,000 paid for carrying out repair work to a contractor without deduction of tax at source would be attracted u/s 40(a)(ia)] 1,05,000 (vi) Expenditure for transfer of carbon credits [Income by way of transfer of Carbon Credits is chargeable to tax under section 115BBG at a flat rate. No deduction is allowed under any provision of the Act in respect of any expenditure or allowance in relation thereto. Since such expenditure is debited to the statement of profit and loss, the same has to be added back] 35,000 (vii) Contribution to electoral trust [Contribution to electoral trust is not allowable as deduction from business profits of the company. Since the expenditure has been debited to statement of profit and loss, the same has to be added back while computing business income] 3,00,000 (viii) Advertisement in brochure of a political party [Advertisement charges paid in respect of brochure published by a political party is not allowable as deduction from business profits of the company as per section 37(2B). Since the expenditure has been debited to statement of profit and loss, the same has to be added back while computing business income] 40,000 (ix) Interest to co-operative bank not paid on or before the due date [Disallowance under section 43B would be attracted for A.Y.2026-27, since the interest was not paid on or before the due date of filing of return] 2,60,000 (x) Contribution towards pension scheme of employees [Contribution towards pension scheme referred to in section 80CCD of employees is allowed only to the extent of 14% of salary of the employee in the P.Y. i.e., ₹ 1,40,000 being 14% of ₹ 10,00,000. Therefore, the excess contribution of ₹ 50,000 [i.e., ₹ 1,90,000 – ₹ 1,40,000] is disallowed u/s 36(1)(iva). 50,000 35,19,000 Add: Amount taxable but not credited to statement of profit and loss 1,07,19,000 A(2) Expenditure pertaining to previous financial year [Cash payment in excess of ₹ 10,000 made in the current year in respect of expenditure allowed on mercantile basis in the previous financial year, would be deemed as income in the current year as per section 40A(3A)] 35,000 1,07,54,000 Less: Items credited to statement of profit and loss, but not includible in business income / permissible expenditure and allowances (i) Unrealised rent [Unrealised rent in respect of commercial property is taxable under the head "Income for house property". Since the said rent has been credited to the statement of profit and loss, the same has to be deducted while computing business income] 3,80,000 (ii) Dividend received from specified foreign company [Dividend received from specified foreign company is taxable under the head "Income from other sources". Since the said dividend has been credited to the statement of profit and loss, the same has to be deducted while computing business income] 1,60,000 (iii) Profit from hedging contract [Hedging contract is entered into for safeguarding against any loss that may arise due to currency fluctuation. The profit from such contract entered into for meeting loss in foreign currency payments towards imported printing machinery has to be adjusted against the cost of machinery. Since the said profit has been credited to the statement of profit and loss, the same has to be deducted while computing business income] 3,00,000 (iv) Interest from bank fixed deposit [Interest on fixed deposit is taxable under "Income from Other Sources". Since the said interest has been credited to the statement of profit and loss, the same has to be deducted while computing business income] 1,35,000 A(3) Audit fees of P.Y. 2024-25 [30% of ₹ 75,000, being the audit fees disallowed in the P.Y. 2024-25 for non-remittance of TDS on or before due date of filing return of income for P.Y. 2024-25 would be allowed in the year of payment of TDS i.e., P.Y. 2025-26] 22,500 A(4) Transfer of Carbon Credits chargeable to tax under section 115BBG [Income by way of transfer of Carbon Credits chargeable under section 115BBG can be treated as business income or income from other sources, depending upon the facts of the case. In this case, since the question mentions that Sheetal Industries Ltd. is engaged in production and marketing of diversified products, it is logical to assume that the same is in the nature of business income. Since the amount of ₹ 4 lakh has already been credited to statement of profit and loss, no further adjustment is necessary] Nil 9,97,500 97,56,500 Less: Depreciation as per Income tax Rules A(1) Depreciation under section 32 28,00,000 Add: Depreciation @7.5% on ₹ 92 lakhs [₹ 95 lakhs, being imported printing machinery - ₹ 3 lakhs, being profit from hedging contract] since, machinery is put to use for less than 180 days]. 6,90,000 Add: Additional depreciation @10% on ₹ 92 lakhs, since machinery is put to use for less than 180 days². 9,20,000 44,10,000 III Profits and gains from business or profession 53,46,500 Income from Other Sources Dividend from specified foreign company 1,60,000 Interest from banks on fixed deposits (Gross) [Interest on banks on fixed deposits is taxable as "Income from other sources"] [₹ 1,35,000 x 100/90] 1,50,000 3,10,000 Gross Total Income 59,22,500 Less: Deduction under Chapter VI-A Under section 80GGB [Contribution by a company to an electoral trust or registered political party is allowable as deduction, since payment is made otherwise than by cash. Expenditure incurred by an Indian company on advertisement in brochure published by political party tantamount to contribution to such political party] [₹ 3,00,000 + ₹ 40,000] 3,40,000 Total income 55,82,500

Topics: Profits and Gains of Business or Profession, Deductions from Gross Total Income

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