And notifications and circulars issued upto

Mr. Akhil, an Indian citizen got a job offer from M/s Wellbeing Inc., a Dubai-based company of AED 10,500 per month. He left for Dubai on 29.3.2023 and joined M/s Wellbeing Inc. on 1st April 2023. He returned to India on 15.12.2023 on leaves for 15 days. On 23.12.2023, he went on 7 days tour to Bali with his wife and son. Thereafter, he directly went to Dubai with his wife and son. On 16.12.2023, he purchased a tour package for Bali from Make Your Trip, an Indian tour operator for which he paid ` 7,50,000 towards flight tickets and hotel accommodation. During F.Y. 2023-24, he has business income of ` 4,20,000 from a retail shop in India and interest on fixed deposit and savings account with Canara Bank of ` 1,20,000 and ` 8,000, respectively.

He is not liable to pay any tax in Dubai. Assume 1 AED = ` 23.

(d) No tax is required to be collected at source

(d) ` 5,40,000

Case Scenario II

Seva Niketan, a charitable trust registered under section 12AB runs an educational institution, which is engaged solely in education and a hospital for treatment of persons suffering from mental disorder solely for philanthropic purposes. The trust furnished the following information:

(vi) Amount paid to another trust registered u/s 12AB by way of donation of ` 10 lakhs. Out of the said amount ` 2 lakhs are given as corpus donations.

(vii)` 6 lakhs, being the amount set apart in the P.Y.2022-23 by the trust for charitable purposes u/s 11(2) utilized in the P.Y. 2023-24 for making donation to another charitable trust, whose object is also education.

(c) No, it cannot do so since aggregate receipts from education and hospital exceed ` 5 crores.

(d) No, it cannot do so due to the reasons mentioned in (b) and (c) above.

(a) ` 36.8 lakhs
(b) ` 25 lakhs
(c) ` 38 lakhs
(d) ` 30 lakhs
11. Seva Niketan claims that anonymous donations received during F.Y.

2023-24 are not liable to be taxed under section 115BBC(1)(i). Is the claim of trust valid? If not, determine the tax leviable under section 115BBC.

Co-operative society regularly files its return of income However, Mr. Arjun has not filed his return of income for the last three years.

Would cash withdrawals by Mr. Arjun and XYZ Co-operative society during the P.Y. 2023-24 attract deduction of tax at source? If yes, how much tax would be deductible by ABC bank.

(viii) Excess on sale of unlisted shares - ` 15 lakhs (Sold on 15th February 2024).

Additional Information:

16. The Commissioner of Income-tax issued notice to revise the order passed by an Assessing Officer under section 143. During the pendency of proceedings before the Commissioner, on the basis of material gathered during survey under section 133A after issue of the first notice, the Commissioner of Income-tax issued a second notice, the contents of which were different from the contents of the first notice. Examine whether the action of the Commissioner is justified as to the second notice.

17. In respect of Mr. Naksh, who is engaged in the export of fabrics, information is flagged as per the risk management strategy formulated by the CBDT for A.Y.2020-21, A.Y.2021-22, A.Y.2022-23 and A.Y.2023-24.

(iii) established a leather goods manufacturing factory in Malaysia on 15th April 2020.

(ii) interest in respect of self-occupied property of ` 1,80,000;

(iii) interest on bank fixed deposits ` 1,60,000.

(iv) Dividend from shares held in Country ‘A’ where dividend was declared and paid in March, 2024 =USD 10,000;

20. ABC (P) Ltd., Bangalore is engaged in the manufacture of electronic goods and exporting the same to various associated and other enterprises across Southeast Asia. The report with respect to its international transactions with AE has been furnished for all years. The company has applied for APA in respect of the transactions with its AE. Application was filed on 15th February 2023 which was signed on 5th May 2023.

The company also applied in respect of the international transactions to which APA applies for rollback benefit which was agreed and signed in January 2024. The details of the status of income tax assessments are as follows:

completed by making reference to the TPO who enhanced the arm’s length price of the international transaction by ` 500 lakhs.

	SUGGESTED ANSWERS/HINTS

Computation of tax liability of Shubh Fragrance Ltd. for the A.Y. 2024-25 under section 115JB

Note - Shubh Fragrance Ltd. is eligible for concessional rate under section 115BAA @25.168% i.e., tax@22% plus surcharge@10% plus