DT Mock Test Paper Solution – 1

CA Final Examination, November, 2018

Expected Questions Set for November, 2018 CA Final DT Exams for New and Old Syllabus.

Note: Students are expected to complete the paper and do write at the end the total time taken to complete the
paper. This Mock Test Paper has to be solved by students themselves.

[Total Marks: 100 Marks]

1) Answer All The Questions:

a) Mr. X was the owner of a Freehold land. In April 2017, he entered into a collaboration agreement
with Arihant Builders for developing the property. According to the terms of the agreement, Arihant
Builders were to develop, construct, and put up a building consisting of four independent floors –
ground floor, first floor, second floor and third floor with terrace at its own cost. Mr. X handed over
to Arihant Builders, the physical possession of the entire property, for the limited purpose of
development. Arihant Builders was to get the third floor plus the undivided interest in the land to
the extent of 25% for its exclusive enjoyment. The remaining floors (i.e., the ground floor, first and
second) were to be handed over to Mr. X after construction.
The cost of construction of each floor was Rs. 1 crore, which was borne by Arihand Builders. In
addition to the cost of construction incurred by Arihant Builders on development of the property, a
further amount of Rs. 5 crore was payable by Arihant Builders to Mr. X as consideration against the
rights of Mr. X. Part completion certificate of ground, first and 2nd floor was received on 31/03/2018.
The SDV as on the said date was Rs. 50 lakhs, 60 lakhs, 75 lakhs respectively.
You are required to discuss and resolve the following issues arising in the assessment of Mr. X as a
result of the above transaction –
(i) What is the year of chargeability of the capital gains on transfer of land?
(ii) For computation of capital gains, what should be the full value of consideration accruing as a
result of transfer of the capital asset?
(iii) Is Mr. X eligible for exemption under section 54F?
(iv) If the answer to (ii) is yes, whether exemption is to be restricted to the cost of construction of
one independent floor, on the reasoning that the floors given to Mr. X contained independent
residential units having seprate entrances and therefore, cannot quality as a single residential
unit?
[12 Marks]
Solution:
(i) Where an individual/HUF has entered into a joint development agreement with a builder,
then subject to section 45(5A), Capital Gains arising to the individual on transfer of such
land/building to the builder shall be taxable as income of the previous year in which the
certificate of completion for whole or part of the project is issued by the competent
authority.
In the present case the part completion certificate of ground, first and 2nd floor was received
on 31/03/2018. Therefore the year of chargeability of capital gains arising on transfer of land
shall be P.Y. 2017-18.
(ii) As per Section 45(5A) the stamp duty value of the share of owner of land/ building in the
developed property on the date of issuing of said certificate of completion, as increased by
any monetary consideration received, if any, shall be deemed to be the full value of
consideration received or accruing as a result of the transfer of the capital asset.
 Therefore in the present case the FVC = Rs. 50 lakhs + Rs. 60 lakhs + Rs. 75 lakhs + Rs. 5 crore
= Rs. 6.85 crore.
(iii) Yes, Mr. X is eligible for exemption under section 54F. Since the cost of construction of the
floors handed over to Mr. X has been included in the full value of consideration, the same
would also represent investment by Mr. X in residential house. Hence, Mr. X is eligible for
exemption under section 54F.
(iv) Section 54F uses the expression “residential house” and not “residential unit”. Section 54F
requires the assessee to acquire a "residential house" and so long as the assessee acquires a
building, which may be constructed, for the sake of convenience, in such a manner as to
consist of several units which can, if the need arises, be conveniently and independently
used as an independent residence, the requirement of the section should be taken to have
been satisfied. There is nothing in the section which requires the residential house to be
constructed in a particular manner. The only requirement is that it should be for residential
use and not for commercial use. The physical structuring of the new building, whether lateral
or vertical, should not come in the way of considering the building as a residential house.
The fact that the residential house consists of several independent units cannot be
permitted to act as an impediment to the allowance of the exemption under section 54F. It is
neither expressly nor by necessary implication prohibited. Therefore, Mr.X is entitled to
exemption of capital gains in respect of investment of Rs. 3 crores in the residential house,
comprising of independent residential units handed over to him.

b) Examine the tax consequence for Assessment Year 2018-19 in respect of fees for technical services
(FTS) received by Mr. Tom Sawyer, a non-resident, from Ganga Ltd., an Indian company, in
pursuance of an agreement approved by the Central Government, if –
a) India has no Double Tax Avoidance Agreement (DTAA) with Country A
b) India has a DTAA with Country A, which provides for taxation of such FT S @5%.
c) India has a DTAA with Country A, which provides for taxation of such FTS @15%.
The technical services are utilised by Ganga Ltd. for its business in Calcutta. Assume that Tom Sawyer
is a resident of Country A and he has no fixed place of his profession in India.
Would your answer change if he has a fixed place of his profession in India and he renders technical
services through that place? Examine, in a case where India has no DTAA with Country A.
[8 Marks]
Solution:
As per section 9(1)(vii)(b), income by way of fees for technical services payable by a resident is
deemed to accrue or arise in India, except where the fees is payable, inter alia, in respect of
services utilized in a business or profession carried on by such person outside India. In this case, since
Ganga Ltd. utilizes the technical services for its business in Calcutta, the fees for technical services
payable by Ganga Ltd. is deemed to accrue or arise in India in the hands of Mr. Tom Sawyer.
In accordance with the provisions of section 115A, where t he total income of a non- corporate non-
resident includes any income by way of royalty or fees for technical services other than the income
referred to in section 44DA(1), received from an Indian concern in pursuance of an agreement made
by him with the Indian concern and the agreement is approved by the Central Government, then,
the special rate of tax at 10% of such fees for technical services is applicable. No deduction would
be allowable under sections 28 to 44C and section 57 while computing such income.
Section 90(2) makes it clear that where the Central Government has entered into a DTAA with a
country outside India, then, in respect of an assessee to whom such agreement applies, the
provisions of the Act shall apply to the extent they are more beneficial to the assessee. Therefore, if
the DTAA provides for a rate lower than 10%, then, the provisions of DTAA would apply.
a) In this case, since India does not have a DTAA with Country A, of which Tom Sawyer is a
resident, the fees for technical services (FTS) received from Ganga Ltd., an Indian company,
would be taxable @10%, by virtue of section 115A.
 b) In this case, the FTS from Ganga Ltd. would be taxable @5%, being the rate specified in the
DTAA, even though section 115A provides for a higher rate of tax, since the tax rates
specified in the DTAA are more beneficial. However, since Tom Sawyer is a non-resident, he
has to furnish a tax residency certificate from the Government of Country A for claiming such
benefit. Also, he has to furnish other information, namely, his nationality, his tax
identification number in Country A and his address in Country A.
c) In this case, the FTS from Ganga Ltd. would be taxable @10% as per section 115A, even
though DTAA provides for a higher rate of tax, since the provisions of the Act (i.e. section
115A in this case) are more beneficial.
If Mr. Tom Sawyer has a fixed place of profession in India, and he renders technical services through
the fixed place of profession, then, by virtue of section 44DA, such income by way of fees for
technical services received by Mr. Tom Sawyer from Ganga Ltd., India, would be computed under
the head "Profits and gains of business or profession" in accordance with the provisions of Income-
tax Act, 1961, since technical services are provided from a fixed place of profession situated in India
and fees for technical services is received from an Indian concern in pursuance of an agreement with
the non-resident and is effectively connected with such fixed place of profession. No deduction
would, however, be allowed in respect of any expenditure or allowance which is not wholly and
exclusively incurred for the fixed place of profession in India.
Mr. Tom Sawyer is required to keep and maintain books of account and other documents in
accordance with the provisions contained in section 44AA and get his accounts audited by an
accountant and furnish the report of such audit in the prescribed form duly signed and verified by
such accountant along with the return of income.
It may be noted that the concessional rate of tax@10% under section 115A would not apply in this
case.

2) Answer All The Questions:

a) A Pvt. Ltd., a new start up, incorporated on 01/08/2016, was engaged in development &
manufacturing of new eligible product. The company had 10 shareholders each holding 10% equity
shares at the time of incorporation of the company.
In order to expand its business further, it has raised funds through private equity placement (20%
from outside India) on 01/06/2017. Although the existing shareholders held their shares, the revised
shareholding of each of them dropped to 4%, the balance 60% being held by the private equity
investors. The Net Profit of the company for the previous year 2017-18 is Rs. 50 Lakhs after debit and
credit of the following:
(i) Rs. 10 Lakhs paid to Foreign JV partner towards access of customer database and to get 2
senior employee of the JV company on the payroll of the assessee company.
(ii) Rs. 5 Lakhs credited to P/L account on account of exchange rate fluctuation towards raising
the share capital from the foreign country. The money raised was applied towards working
capital requirement of the company.
(iii) Rs. 10 Lakhs was paid on 01/08/2017 towards purchase of heavy duty spare parts which was
essential to avoid the breakdown of machines. 50% of the amount was paid in cash.
(iv) During the previous year the company paid Rs. 25 Lakhs to authorised agency towards
feasibility study and market survey for the expansion of its business.
(v) Rs. 1 Lakh paid to the Registrar of Company towards increasing its authorised share capital.
(vi) Rs. 3 Lakh was debited to Profit and Loss Account being expenses towards issue of share
capital.
Additional Information:
 (i) B/f business loss and unabsorbed depreciation of AY 2017-18 is Rs. 10 Lakhs and Rs. 5 Lakhs
respectively.
(ii) The following details pertains towards expansion of business and the issue of shares:
- Cost of project - Rs. 1,300 Lakhs
- Share Capital issued of Rs. 1,000 Lakhs at F.V. (Rs. 100 each)
- Share Premium - Rs. 500 Lakhs
- Debenture - Rs. 300 Lakhs (to be redeemed after 20 years)
- The FMV of the shares - Rs. 140 each.
(iii) The company acquired the land towards its expansion of business. The cost of land is Rs. 2
crores. 50 percent of the cost of land was to be borne by the Central Government towards
promotion of the startup business.
(iv) The expansion process was completed on 31/03/2018.
Compute the total income of the company.
[16 Marks]
Solution:
Computation of Total Income
Of A Pvt. Ltd.
For the A.Y. 2018-19
Particulars Amount Amount
(in lakhs) (in lakhs)
Net Profit as per the books 50
(+) Amount paid to foreign JV partner NIL
- [The SC in IBM Global Services India Ltd. has held that the
amount paid to the foreign JV partner towards sharing of
the customer base is not a capital expenditure. Further the
amount paid towards obtaining the employee of the foreign
company is for the purpose of business & profession as it
saves the training cost on the recruitment]

(-) Amount credited towards exchange fluctuation 5

- [The Delhi HC in Jagjit Industries Ltd. has held that exchange
gain on raising share capital from foreign country is in the
nature of capital receipt irrespective of the purpose for
which it is raised or the manner in which it is applied]

(+) Expenditure on spare parts

- [As per ICDS – V where the spare can be used only in 10
connection with a particular asset and its use is irregular
then such expenses shall be capitalised]

(-) Depreciation on above expenditure

Actual Cost Rs. 10 lakhs (1.75)
(-) Payments in cash > Rs. 10,000 Rs. 5 lakhs
WDV Rs. 5 lakhs
(i) Depreciation u/s 32(1)(ii) @ 15% 75,000
(ii) Depreciation u/s 32(1)(iia) @ 20% 1,00,000

(+) Expenses towards expansion of business by raising share

capital is a capital expenditure and hence shall not be allowed as 25
deduction.
(-) Deduction u/s 35D:
Step 1: [5% of cost of project (1300) Rs. 65 (5)
OR
5% of Capital Employed (1000+300)]
Whichever is higher
Step 2: [Preliminary Exps. (25) Rs. 25
OR
Qualifying Amount of Step 1 (65)]
Whichever is lower
∴ Deduction = 1/5 x Rs. 25

(+) Exps. Towards increase in authorised share capital & towards

issue of share capital is a capital expenditure and hence 4
disallowed as held by the SC in brook bond India Ltd.

(+) Subsidy on land

- [Out of the total cost of Rs. 200 lakhs, 50% is borne by the 100
Govt. As per ICDS VI. Subsidy or grant given by the
government or any authority in respect of the asset other
than depreciable asset to which explanation 10 to Section
43(1) is applicable shall be considered as Income u/s 2(24)
and accordingly chargeable to tax]
177.25
(-) B/f business losses
- [The benefit of Section 79(b) shall be available since the 10
company being eligible startup company has issued new
share capital while all the shareholders of the company
before the fresh issue continues to hold those shares on the
last day of the P.Y. to which the loss is sought to be set off,
even though their overall voting power went below 51%]

(-) Unabsorbed Depreciation u/s 32(2) 5

Profits and Gains from Business or Profession 162.25

Income from Other Sources

- U/s 56(2)(viib) 80.00
Since the issue price > facevalue [1500 (-) 1400] x 80%
(The section applies only when the share is issued to the
resident since 20% of the funds is raised outside India, only
80% of the difference between issued price and the FMV
shall be chargeable under the said section)
Gross Total Income 242.25
(-) Deduction under Chapter VIA
- u/s 80IAC (62.25)
[100% of the profit derived from the eligible business:
162.25(-) 100:
The land subsidy was not in respect of manufacturing or
selling activities of the product and hence does not have a
direct nexus between profit and gains derived from the
activities of undertaking]
Total Income 180
3) Answer All The Questions:
a) Z Ltd. An Indian multinational group has a holding company A Co. in Singapore for global reporting
purpose. The A. Co. also has 100% downstream subsidiaries B. Co. and C. Co. in Singapore and D. Co.
in China. The POEM of A Co. is in India and is exercised by Indian Multinational Company of the
group. The subsidiaries B, C and D are engaged in active business outside India. The meetings of BOD
of B Co., C. Co. and D Co. are held in their respective countries.
D Co. transfers process knowhow to Z Ltd. For which it is paid royalty at Rs. 15 crore. Similar process
transfer made by XY Ltd. To TN Ltd. fetched the former a royalty of Rs. 12 crore. (Both XY Ltd. & TN
Ltd. are unrelated party).
Z Ltd. processes the goods and sells to B Co. the finished product for Rs. 85 Crore. Similar goods sold
by Z Ltd. to E Co. were for Rs. 90 crore. The only difference being the price charged to E Co. was cum-
warranty. The warranty charges could be estimated to Rs. 2.5 crore.
During the year Z Ltd. took a loan of Rs. 150 crore @ 10% rate of interest. The interest expenses
claimed as deduction was Rs. 7.5 crore. The loan was guaranteed by C Co. EBITDA of Z Ltd. was Rs. 20
crore.
Z Ltd. distributes the common H.O. expenditure to A, B, C & D Co. The common H.O. expenses are Rs.
30 crores. The expenses debited in its profit and loss account are Rs. 30 crore, whereas the recovery
credited to P&L Account is Rs. 20 crore. The relative contributions of the entities are 50% (Z Ltd.),
10% (A), 20% (B), 10% (C), 10% (D).
You are required to:
(i) Ascertain residential status of A Co., B Co., C Co. and D Co.
(ii) Workout the total income after carrying necessary adjustments. The total income before these
adjustments is Rs. 25 crore. Also discuss the consequences aftermath.
(iii) What could be the possible reporting compliance and who could be responsible to report the
same?
[12 Marks]
Solution:
(i) W.e.f. AY 2017-18, a company would be resident in India in any previous year if:
- It is an Indian Company, or
- Its place of effective management, in that year, is in India.
“Place of Effective Management” (POEM) means a place –
 where key management and commercial decisions that are necessary for the business of an
entity as a whole
 are in substance made.
Based on above the residential status for AY 2018-19 of various companies is as under:
1 Z Ltd. Resident in India as it is an Indian Company.
2 A Co. The foreign company A Co. shall be considered as tax resident of India for AY
2018-19 as the question clearly provides that its POEM is exercised by the
Indian Co. Z Ltd.
3 B Co., Merely because the POEM of the intermediate holding company A Co. is in
C. Co., India, the POEM of its subsidiaries shall not be taken to be in India. Each
D Co. subsidiary has to be examined separately. As indicated in the facts, since B Co.,
C Co., and D Co. are independently engaged in active business outside India and
majority of Board meetings of these companies are also held outside India, the
POEM of B Co., C Co. and D Co. shall be presumed to be outside India.

(ii)
 Z Ltd., A Co., B Co., C Co. and D Co. are all associated enterprises falling within the scope of
Sec. 92A.
  Further the transactions entered by Z Ltd. with its AE are in the course of International
Transaction as its AE are non-resident.
 As per Section 92(1) any income arising from an international transaction shall be
computed having regard to the arm’s length price.
 As per section 92(2) where in an international transaction, two or more associated
enterprises enter into a mutual agreement for the allocation or apportionment of any cost
or expenses incurred, the cost or expense allocated or apportioned to any such enterprise
shall be determined having regard to the arm’s length price.
 Further as per section 92(3), the provisions of the section shall not apply in a case where
the computation of income u/s 92(1) or 92(2) has the effect of reducing the income
chargeable to tax or increasing the loss, as the case may be.
Keeping in mind the above statutory provisions, the Total Income of Z Ltd. for AY 2018-19 is
computed as under:
Total Income of Z Ltd. for AY 2018-19
Most TP Adjustment Amount (Rs.)
Particulars Appropriate (Rs. In crores) (in crores)
Method
Total Income before transfer pricing
adjustment --- --- 25
(+) T.P. Adjustments (Primary):
(i) Royalty paid to D Co. towards
transfer of process knowhow CUP (15-12) 3

(ii) Sales of goods to B Co. at ex- CUP 90 – 2.5 87.5

warranty (-)
transfer
price 85.0 2.5

(iii) Allocation of HO expenditure:

Since the recovery made by Z Ltd. --- --- ---
is more than the relative
contribution of its AE, no
adjustments are required in view
of Section 92(3).
Total Income after primary adjustment 30.5
(+) Adjustment u/s 94B
Z Ltd. pays interest in respect of
debt which is guaranteed by its AE.
Interest paid in excess of 30%
EBITDA shall be disallowed and will
be allowed to be carried forward. It
is assumed that the rate of interest
is at arm’s length. 1.5
[7.5 (-)(30% x 20)]
Total Income Rs. 32 Crore

Note: Since the amount of primary adjustment made in case of Z Ltd. for AY 2018-19 (Rs. 5.5
crore) exceed Rs. 1 crore, the assessee may be liable to carry out secondary adjustment u/s
92CE, if the amount of primary adjustment is not repatriated within the time limit prescribed in
Rule 10CB.
(iii) As per section 286 r.w. Rule 10DA and Rule 10DB, the following reporting compliance shall be
applicable for Z Ltd./A Co.:
  MASTER FILE: Rule 10DA

Whether the Furnish report electronically in Part A (only)

consolidated NO
of Form No. 3CEAA on or before the due
group revenue date of filing ROI.
> Rs. 500 cr?

NO
YES

Whether –
 Aggregate value of international transaction during accounting year (as per books)
exceeds Rs. 50 crore?
OR
 Aggregate Value of international transactions in respect of purchase, sale, transfer,
lease or use of intangible property during the accounting year exceeds Rs. 10 cr.?
YES

Furnish report electronically in Part A & Part B of Form 3CEAA on or before the date of filing
of the ROI.

Assuming that the consolidated group revenue exceeds Rs. 500 crores, the assessee would be
required to furnish report electronically in Part A & Part B of Form 3CEAA on or before the date
of filing of ROI. Further the ggregate value of International Transactions as per per books
exceeds Rs. 50 crore. Also the aggregate value of international transaction involving intangible
property as per books exceeds Rs. 10 crore.

Country by Country reporting (CbCr)

Section 286 r.w. Rule 10DB requires submission of CbCr in the case of an international group for
an accounting year, if total consolidated group revenue exceeds Rs. 5500 crore.
Assuming that the above threshold in not crossed CbCr is not required to be filed.

b) Bingo Inc. (resident of UK), engaged in shipping business had appointed 4 agents in India for booking
cargo and for clearing goods. Bingo Inc. had set up and maintained ‘Vault’ (an integrated and
centralized communication system) for its agents across globe. Bingo Inc. incurred Rs. 1 crore on
developing the system. The Indian agents shared cost of system & paid Rs. 10 Lakh on pro-rata basis
without deducting tax, contending to be reimbursement of expenses. The AO treated the payments
by agents as fees for technical services and issued notice to agents u/s 201(1) treating them assessee
in default. Examine the transaction.
[4 Marks]
Solution:

Director of Income-Tax (International Taxation) v. A.P.

Moller Maersk [2017] – SC
Facts: Provision:
1. The assessee was a Sec.9(1)(vii) provides that income by way of fees for technical services
foreign company payable by a person who is a resident in India is deemed to accrue or
engaged in shipping arise in India.
business and was a Analysis:
tax resident of 1. Centralised communication system was an integral part of the
Denmark. international shipping business of the assessee
2. The assessee had The Supreme Court observed that, for the sake of convenience of its
agents working for it agents, the assessee had set up a centralised communication system
across the globe, who which was an integral part of the international shipping business of
booked cargo and the assessee and common facility was provided to all the agents.
acted as clearing
agents. 2. Sharing of Expenditure Towards Common Facilities:
3. In India, the assessee The expenditure incurred for running this system was shared by all
had three agents. the agents and payments to assessee were merely as
4. The assessee had set reimbursement of expenses incurred. The payments could not be
up and maintained a treated as fees for technical services.
vertically integrated
communication 3. Transaction at ARM’s Length:
system called Maersk No profit element was embedded in the payments, also the TPO had
net system in order accepted that the payments were in the nature of reimbursement (in
to help all its agents. assessee’s hands at arm's length)
5. The agents paid for
the system on a pro 4. DTAA applied:
rata basis. Moreover, the Revenue authorities had accepted that assessee’s
6. The Assessing Officer freight income in the relevant assessment years was not chargeable
contended that the to tax as it arose from the operation of ships in international waters
amounts paid by the in terms of Article 9 of the India and Denmark DTAA (DS Comment:
Indian agents were as per Article 9, shipping profits are taxable in the country where
fees for technical POEM is established).
services taxable
under Article 13(4) of 5. Business Profit v/s Technical Services:
the India and Once that was accepted and it was found that the communication
Denmark DTAA. system was an integral part of the shipping business, payments
7. The assessee argued received from agents could not be treated as in lieu of any technical
that the arrangement services.
was merely a cost
sharing system and 6. It was only a facility that was allowed to be shared by the agents
the payments were and it can not be treated as any technical services
only aSC relied on Kotak Securities Ltd. ruling wherein it was held that “use
reimbursement of of facility does not amount to technical services, as technical services
expenses. denote services catering to the special needs of the person using
them and not a facility provided to all”; Thus, SC ruled that “it is only
a facility that was allowed to be shared by the agents and by no
stretch of imagination it can be treated as any technical services
provided to the agents”
Issue Raised: Conclusion:
Whether payments made The Supreme Court, accordingly, held that amounts paid by Indian
by the agents, , to use a agents to the non-resident company would not be liable to tax as fee
 centralized for technical services under Article 13(4) of the India and Denmark
communication system DTAA.
maintained by the
assessee-company, can
be treated as fees for
technical services?

4) Answer All The Questions:

a) The assessment of Mr. Hari for A.Y.2011-12 was made on 28.3.2013 making an addition of Rs.
3,25,000 in respect of certain income received during the P.Y.2010-11. The assessee contested the
addition before Commissioner (Appeals) but lost the case. The Appellate Tribunal passed an order on
26.2.2018 holding that the said income was not taxable in the P.Y.2010-11 but the same was taxable
in the year of accrual, being P.Y.2005-06 relevant to A.Y.2006-07. The Assessing Officer issued notice
under section 148 for A.Y.2006-07 in March 2018 bringing to tax the sum of Rs. 3,25,000. Is the
notice for reassessment valid?
[4 Marks]
Solution:
Section 149(1) provides the time limit for issue of notice under section 148 for assessment,
reassessment or re-computation where income has escaped assessment. The time limit prescribed
under section 149(1) in a case where income escaping assessment exceeds Rs. 1 lakh is 6 years from
the end of the relevant assessment year. In this case, the relevant assessment year is A.Y.2006-07,
being the year in respect of which the income exceeding Rs. 1 lakh has escaped assessment. The six
year time limit under section 149(1) for issuing notice under section 148 relating to A.Y.2006-07
expires on 31.3.2013. In this case, the notice under section 148 is issued in March, 2018, which is
outside the six year time limit prescribed under section 149(1).
The restriction of time limit under section 149(1) is, however, not applicable where notice under
section 148 is issued for making an assessment, reassessment or re-computation to give effect to
any finding or direction contained in an order passed by any authority in any proceeding by way of
appeal, reference or revision or by a Court in any proceeding under any other law. This relaxation is
contained in section 150(1).
However, such relaxation will not apply where any such assessment or reassessment relates to an
assessment year in respect of which an assessment or reassessment could not have been made at
the time the order which was the subject matter of appeal, reference or revision, as the case may
be, was made on account of such assessment or reassessment having become time-barred at that
point of time itself. This restriction is contained in section 150(2). The relaxation contained in section
150(1) is, therefore, subject to the restriction contained in section 150(2).
In this case, since the notice under section 148 was issued for the purpose of making reassessment
to give effect to an appellate order, the restriction contained in section 149(1) does not apply. The
relaxation under section 150(1) will apply in this case, since the order which was the subject matter
of appeal was passed on 28.3.2013, which is within the six year time limit from the end of the
relevant assessment year, i.e., A.Y.2006-07. Therefore, since the original order which was the subject
matter of appeal was passed on 28.3.2013, the relaxation contained in section 150(1) will apply.
Consequently, the notice issued under section 148 by the Assessing Officer in March 2018, in this
case, would be valid.

b) Does the Appellate Tribunal, under section 254(2), have the power to review or re- appreciate the
correctness of its earlier decision on merits? Also, discuss whether the Tribunal has the power there
under to recall an order in entirety, to rectify a mistake apparent from record. In this context,
distinguish between the power to review and power to recall, with the aid of recent case laws.
 [4 Marks]
Solution:
Section 254(2) specifically empowers the Appellate Tribunal to amend any order passed by it, either
suo motu or on an application made by the assessee or Assessing Officer, with a view to rectifying
any mistake apparent from record, at any time within 4 years from the date of passing the order
sought to be amended.
The powers of the Tribunal under section 254(2) relating to rectification of its order are very limited.
Such powers are confined to rectifying any mistake apparent from the record. The mistake has to be
such that for which no elaborate reasons or inquiry is necessary. Accordingly, the re-appreciation of
evidence placed before the Tribunal during the course of the appeal hearing is not permitted. It
cannot re-adjudicate the issue afresh under the garb of rectification. This issue came up for
consideration before the Punjab & Haryana High Court in the case of CIT vs. Vardhman Spinning
(1997) 226 ITR 296, wherein it was observed that the jurisdiction to review or modify orders passed
by the authorities under the Act cannot be inferred on the basis of a supposed inherent right.
The Delhi High Court, in Lachman Dass Bhatia Hingwala (P) Ltd. v. ACIT (2011) 330 ITR 243
(Delhi)(FB), observed that the justification of an order passed by the Tribunal recalling its own order
is required to be tested on the basis of the law laid down by the Apex Court in Honda Siel Power
Products Ltd. v. CIT (2007) 295 ITR 466, dealing with the Tribunal’s power under section 254(2) to
recall its order where prejudice has resulted to a party due to an apparent omission, mistake or error
committed by the Tribunal while passing the order. Such recalling of order for correcting an
apparent mistake committed by the Tribunal has nothing to do with the doctrine or concept of
inherent power of review. It is a well settled provision of law that the Tribunal has no inherent
power to review its own judgment or order on merits or re-appreciate the correctness of its earlier
decision on merits. However, the power to recall has to be distinguished from the power to review.
While the Tribunal does not have the inherent power to review its order on merits, it can recall its
order for the purpose of correcting a mistake apparent from the record.
When prejudice results from an order attributable to the Tribunal’s mistake, error or omission, then
it is the duty of the Tribunal to set it right. The Delhi High Court observed that the Tribunal, while
exercising the power of rectification under section 254(2), can recall its order in entirety if it is
satisfied that prejudice has resulted to the party which is attributable to the Tribunal’s mistake, error
or omission and the error committed is apparent.
Thus, while the Tribunal does not have the power to review or reappreciate the correctness of its
earlier decision on merits under section 254(2), it, however, has the power to recall its order in
entirety to rectify a mistake apparent from record.

c) Biotech Ltd. filed its return of income for A.Y.2018-19 on 30th September, 2018. In computing its
business income, it had claimed a weighted deduction @150% of the expenditure of Rs. 22 lakhs
(including cost of building Rs. 10 lakhs) on in-house scientific research under section 35(2AB). The
assessee had clearly disclosed the bifurcation of expenditure of Rs. 22 lakhs in its return of income.
The Assessing Officer, disallowed Rs. 5 lakhs, being the excess 100% of cost of building which was
claimed as weighted deduction under section 35(2AB), since the same was eligible only for
deduction@100% under section 35(1)(iv) read with section 35(2). He also levied penalty under
section 270A @200%. Biotech Ltd. agreed with the disallowance made but contended that there no
misreporting of particulars of income so as to attract penalty under section 270A, since it has
disclosed all the particulars of income, including the bifurcation of expenditure in respect of which
deduction was claimed under section 35(2AB). Discuss the correctness of the Biotech Ltd.’s
contention.
[4 Marks]
Solution:
The issue under consideration in this case is whether making an incorrect claim in the return of
 income would tantamount to underreporting of income or furnishing of inaccurate particulars for
attracting the penal provisions under section 270A when no information given in the return of
income is found to be incorrect.
This issue came up before the Supreme Court in CIT v. Reliance Petro Products Pvt. Ltd. (2010) 322
ITR 158. The Supreme Court observed that in order to attract the penal provisions of section 270A,
there has to be underreporting of income or furnishing inaccurate particulars of income. Where no
information given in the return is found to be incorrect or inaccurate, the assessee cannot be held
guilty of furnishing inaccurate particulars. Making an incorrect claim (i.e. a claim which has been
disallowed) would not, by itself, tantamount to underreporting of income.
The Apex Court held that where there is no finding that any details supplied by the assessee in its
return are incorrect or erroneous or false, there is no question of imposing penalty under section
270A. A mere making of a claim, which is not sustainable in law, by itself, will not amount to
underreporting of income regarding the income of the assessee.
Applying the rationale of the above Supreme Court ruling to the case on hand, penalty under section
270A cannot be imposed on Biotech Ltd. merely for making an incorrect claim which is not
sustainable in law, since the company had furnished all the details and no information given by the
company was found to be incorrect or erroneous or false.
The contention of Biotech Ltd. is, therefore, correct.

d) Satpura Ltd. has received a notice under section 148 for the Assessment Year 2014-15 on
09/08/2017. It also anticipates similar notice for the Assessment Year 2012-13 and 2013-14 for
which it has already furnished return of income. On examination of the books of account produced,
you have noticed huge amounts of concealed income. As a consultant, what would be your advice to
Satpura Ltd.?
[4 Marks]
Solution:
As per section 245C, an assessee may, at any stage of a case relating to him, make an application in
the prescribed form and manner to the Settlement Commission.
“Case” means any proceeding for assessment which may be pending before an Assessing Officer on
the date on which such application is made.
A proceeding for assessment or reassessment or re-computation under section 147 is deemed to
have commenced from the date of issue of notice under section 148. Where a notice under
section 148 is issued for any assessment year, a proceeding under section 147 shall be deemed to
have commenced on the date of issue of such notice and the assessee can approach the
Settlement Commission for other assessment years as well, even if notice under section 148 for
such other assessment years have not been issued but could have been issued on that date.
However, a return of income for such other assessment years should have been furnished under
section 139 or in response to notice under section 142.
In the case on hand, Satpura Ltd. has received a notice under section 148 for the A.Y.2014-15 and
also anticipates similar notices for the A.Y.2012-13 and A.Y.2013-14, for which return of income
has been furnished. Thus, a proceeding for assessment is pending before an Assessing Officer i.e.,
the basic condition for approaching Settlement Commission is satisfied.
Moreover, since after examination of the books of account, huge amount of concealed income is
also noticed, it is presumed that the second condition that the additional amount of income-tax
payable on the income disclosed in the application should exceed Rs. 10 lakhs has also been
satisfied.
Based on these facts, assuming that the necessary conditions are fulfilled, our advice as consultant
to Satpura Ltd. would be to approach the Settlement Commission to have its case settled and apply
for grant of immunity from penalty and prosecution.

5) Answer All The Questions:

a) Discuss the following issues in the context of the provisions of the Income-tax Act, 1961, with
specific reference to clarification given by the Central Board of Direct Taxes –
(i) Moon TV, a television channel, made payment of Rs. 50 lakhs to a production house for
production of programme for telecasting as per the specifications given by the channel. The
copyright of the programme is also transferred to Moon TV. Would such payment be liable
for tax deduction at source under section 194C? Discuss.
Also examine whether the provisions of tax deduction at source under section 194C would
be attracted if the payment was made by Moon TV for acquisition of telecasting rights of the
content already produced by the production house.
(ii) Mudra Adco Ltd., an advertising company, has retained a sum of Rs. 15 lakhs, towards
charges for procuring and canvassing advertisements, from payment of Rs. 1 crore due to
Cloud TV, a television channel, and remitted the balance amount of Rs. 85 lakhs to the
television channel. Would the provisions of tax deduction at source under section 194H be
attracted on the sum of Rs. 15 lakhs retained by the advertising company?
[5 Marks]
Solution:
(i) The CBDT has, vide Circular No. 4/2016 dated 29.2.2016, clarified that while applying the
relevant provisions of TDS on a contract for content production, a distinction is required to be
made between:
i a payment for production of content/programme as per the specifications of the
broadcaster/telecaster; and
ii a payment for acquisition of broadcasting/telecasting rights of the content already
produced by the production house.
In the first situation where the content is produced as per the specifications provided by the
broadcaster/telecaster and the copyright of the content/programme also gets transferred to the
telecaster/broadcaster, such contract is covered by the definition of the term `work’ in section
194C and, therefore, subject to TDS under that section.
However, in a case where the telecaster/broadcaster acquires only the telecasting/
broadcasting rights of the content already produced by the production house, there is no
contract for ‘’carrying out any work”, as required in section 194C(1). Therefore, such payments
are not liable for TDS under section 194C. However, payments of this nature may be liable for
TDS under other sections of Chapter XVII-B of the Act.
In this case, since the programme is produced by the production house as per the specifications
given by Moon TV, a television channel, and the copyright is also transferred to the television
channel, the same falls within the scope of definition of the term ‘work’ under section 194C.
Therefore, the payment of Rs.50 lakhs made by Moon TV to the production house would be
subject to tax deduction at source under section 194C.
If, however, the payment was made by Moon TV for acquisition of telecasting rights of the
content already produced by the production house, there is no contract for ‘’carrying out any
work”, as required in section 194C(1). Therefore, such payment would not be liable for tax
deduction at source under section 194C.
(ii) The issue of whether fees/charges taken or retained by advertising companies from media
companies for canvasing/booking advertisements (typically 15% of the billing) is 'commission' or
'discount' to attract the provisions of tax deduction at source has been clarified by the CBDT
vide its Circular No.5/2016 dated 29.2.2016.
The Circular draws reference to the Allahabad High Court ruling in the case of Jagran Prakashan
Ltd. and the Delhi High Court ruling in the matter of Living Media Limited. In both the cases, the
Courts have held that the relationship between the media company and the advertising agency
is that of a 'principal-to-principal' and, therefore, not liable for TDS under section 194H. Though
these decisions are in respect of print media, the ratio is also applicable to electronic
media/television advertising as the broad nature of the activities involved is similar.
 In view of the above, the CBDT has clarified that no liability to deduct tax is attracted on
payments made by television channels to the advertising agency for booking or procuring of or
canvassing for advertisements.
Accordingly, in view of the clarification given by CBDT, no tax is deductible at source on the
amount of Rs. 15 lakhs retained by Mudra Adco Ltd., the advertising company, from payment
due to Cloud TV, a television channel.

b) Mr. Rajiv is a retail trader and his total income for the last few years ranged between Rs. 8 lakh to Rs.
10 lakh. He celebrated his 25th wedding anniversary on a large scale on 2nd December, 2017
by hosting a cruise party in the luxury cruise liner “Ocean Princess”, for which he had spent Rs. 30
lakh. The Assessing Officer, in the course of scrutiny assessment of Mr. Rajiv, asked him to explain
the source of such expenditure. The explanation offered by Mr. Rajiv that the same was out of his
savings for the last few years, was not found satisfactory by the Assessing Officer, since a couple of
years ago, he had spent to tune of Rs. 60 lakh on the grand wedding celebrations of his daughter at
Vijayaseshmahal in Chennai. You are required to examine the tax consequences.
[5 Marks]
Solution:

If any expenditure is incurred by an assessee in any financial year in respect of which he is not able
to offer explanation about the source of such expenditure or the explanation offered by him is not
satisfactory in the opinion of the Assessing Officer, then the amount of such unexplained
expenditure may be deemed as income of the assessee for such financial year as per section 69C.
Therefore, in this case, since the Assessing Officer is not satisfied with the explanation offered by Mr.
Rajiv, the expenditure of Rs. 30 lakh incurred by him in the financial year 2017-18 in hosting a grand
cruise party may be deemed as his income for P.Y. 2017-18 as per section 69C.
Further, such unexplained expenditure which is deemed as the income of Mr. Rajiv shall not be
allowed as deduction under any head of income.
Where the total income of Mr. Rajiv includes such unexplained expenditure of Rs. 30 lakh, which is
deemed as his income under section 69C, such deemed income would be taxed at the rate of 60%
as per section 115BBE plus surcharge@25% and cess@3%. The effective rate of tax would be
77.25%.
Further, no basic exemption or allowance or expenditure shall be allowed to him under any
provision of the Income-tax Act, 1961 in computing such deemed income. No set-off of loss is
permissible against such deemed income.
New section 271AAC has been inserted with effect from 1st April, 2017 in the Income-tax Act, 1961
to provide for levy of penalty@10% of tax payable under section 115BBE, in a case where income
determined includes any income referred to in sections 68, 69, 69A to 69D for any previous year.
However, no such penalty would be levied on such income to the extent the same has been included
by the assessee in return of income furnished under section 139 and tax in accordance with section
115BBE has been paid on or before the end of the relevant previous year.

c) For A.Y. 2015-16, the order of assessment was passed on 01/02/2017 in consequence of which
notice of demand was raised u/s 156 demanding additional tax of Rs. 1,50,000/-. The assessee paid
the additional tax on 15/02/2017 and filed as appeal. The CIT(A) on 02/03/2017 cancels the order of
the AO. The order of the CIT(A) is received on the same date.
On the basis of the above answer the following:
(i) Calculate the amount of Interest payable by the department, if the AO gives the effect to the
said order on 17/08/2017. Also suggest the situation under which the AO can with held the
refund.
 (ii) Assuming that the department files a subsequent appeal, and the ITAT maintains the order
of the AO by passing its order on 28/02/2018, what shall be the interest due to the
department considering that the assessee makes the payment of the amount due on
15/03/2018?
(iii) Whether the AO is required to raise a fresh notice of demand towards the sum due arising
out of the order of the ITAT?
[6 Marks]
Solution:
(i) Interest payable to assessee-
 Interest shall be calculated at the rate of 0.5% per month or part thereof from the date of
payment of tax to the date on which the refund is granted.
No interest shall be payable, if the amount of refund < 10% of the tax determined u/s
143(1) or on regular assessment.
Accordingly in the present case for the period 15/2/2017 to 17/8/2017 the interest shall be
calculated as under:
Rs. 1,50,000 x 0.5% x 7 (6 Months and 2 days)
= Rs. 5,250/-
 Where the refund arises out of appeal effect being delayed beyond the time presented u/s
153(5) (i.e. 3 months from the end of the month in which appellate order is received by
CIT), the assessee shall be entitled to receive an additional interest). The Additional interest
on such refund shall be calculated at the rate of 3% per annum, for the period beginning
from the date following the date of expiry of the time allowed u/s 153(5) to the date on
which the refund is granted.
In the present case the appeal order is received on 2/3/2017.
Therefore interest shall be calculated from 1/7/2017 to 17/8/2017 = 48 days.
Interest = [Rs. 1,50,000 x (3/100) x (48/365)]
= Rs. 592
Therefore total interest payable to assessee = Rs. 5,250 + Rs. 592 = Rs. 5,842/-
 For every assessment year commencing on or after the 1st day of April, 2017, where refund
of any amount becomes due to the assessee u/s 143(1) and the AO is of the opinion that
the grant of the refund is likely to adversely affect the revenue, he may, for reasons to be
recorded in writing and with the previous approval of the PCIT or CIT, withhold the refund
up to the date the assessment is made.
Since in the present case the refund is arising in consequence of order of the appellate
authority, the AO cannot withhold the refund.

(ii) In the present case the interest u/s 220 shall be charged for the period from 28/2/2018 till
15/3/2018 in consequence of the demand arising in consequence of the decision of the ITAT.
The interest shall be charged @ 1% per month.
Therefore the amount of interest shall be
Rs. 1,50,000 x 1% = Rs. 1,500/-
(iii) No separate notice of demand is required to be served in respect of the demand arising in
consequence of the order of the appellate authority. The original notice of demand served u/s
156 shall be deemed to be valid till the disposal of appeal by the last appellate authority.

6) Answer All The Questions:

a) Net profit of ABC LLP for previous year is Rs. 20 lakh after the debit and credit of the following:
(i) Dividend received from various domestic companies during the previous year is Rs. 12 lakh.
(ii) Depreciation as per books Rs. 3 lakh.
(iii) Speculation profit on contract of goods settled without obtaining its delivery of Rs. 2 lakh.
(iv) Amount debited includes contribution of Rs. 1 lakh towards national laboratory.
(v) Rs. 2 lakh debited on account of bad debts in respect of debtors taken over of A Pvt. Ltd.
(vi) Rs. 10 lakh being incurred on 30/08/2017 towards replacing the existing ceiling of factory
building which was in a very bad state.
(vii) The arrears of interest on loan taken by A Pvt. Ltd. of Rs. 8 lakh was converted in to a new
loan repayable in 10 equal installment commencing from PY 18-19. The firm claimed the
deduction of arrears of interest on loan.
(viii) Rs. 5 lakh, being sales tax dues of earlier years determined during the year on disposal of
appeals by appellate authorities, for which the firm has furnished a bank guarantee and
claimed deduction.
Additional Information:
Partner A,B,C were equal partner at the time of its formation as they held the shares in the erstwhile
company. Partner A however retired on 31/3/18 to whom the land was distributed by the firm
towards settlement of his dues. The FMV of the land as on 31/3/18 is Rs.90 lakhs . The SDV of the
land as on this date was Rs.100 lakhs.
A Pvt. Ltd. was incorporated on 01/12/2009 in which A,B,C held shares equally. Finding it difficult to
sustain the business being as a corporate entity, it converted itself as LLP on 31/07/2017. The
following are the particulars of A Pvt. Ltd. as on 31-3-17:
a. Unabsorbed depreciation - Rs. 13 Lakhs
b. Business loss Rs. 10 Lakhs (relating to P.Y. 2009-10)
c. Speculative loss of AY 14-15 is Rs. 2 lakhs.
d. Unadjusted MAT credit u/s 115JAA Rs. 8 lakhs
e. WDV of the assets as per 43(6) of the Income Tax Act:
Plant and Machinery (15%) Rs. 60 lakhs
Building (10%) Rs. 20 lakhs
Land (acquired in 2001-2002) is Rs.50 lakhs.
f. VRS expenditure incurred by the company during the P.Y. 2015-16 is Rs.25 lakhs. The
company has been allowed deduction of Rs. 5 lakhs each year for the P.Y. 2015-16 and P.Y.
2016-17 u/s 35DDA.
g. The turnover of the company from P.Y.14-15 to P.Y.16-17 is less than Rs. 60 lakhs in each
year.
Compute the Tax liability of the firm for AY 2018-19.
[12 Marks]
Solution:
Computation of Total Income
Particulars Amount
(Rs. In lakhs)
Net Profit as per Profit and Loss Account 20
Less: Dividend Taxable under the head IFOS (12)
Less: Speculation Profit (2)
Add: Depreciation as per books 3
Bad Debts [Note 2] -
Add: Replacement of Ceiling [Note 3] 10
Add: Arrears of Interest [Note 4] 8
Add: Sales Tax Dues [Note 5] 5
Less: Corresponding depreciation on account of capitalisation of above
expenses (Rs. 10 lakhs x 10%) (1)
Less: Deduction for count to National Laboratory (150% of Rs. 1 lakh) (0.5)
Less: Depreciation in respect of asset received on conversion [Note 8] (7.34)
 Less: VRS Expenses (5)
I) Profits and Gains from Business or Profession 18.16
Less: Brought forward Business Loss [Note 7] (6.67)
11.49
(-) UAD of A Pvt. Ltd. Rs. 13 lakh (Restricted to….) (11.49)
NIL
II) Speculation Profit 2
III) Long Term Capital Loss – Carried Forward (Rs. 46 lakh) -
IV) Income from Other Sources
Dividend taxable u/s 115BBDA (Rs. 12 lakh – Rs. 10 lakh) 2
Total Income 4

Computation of Tax Liability

Particulars Amount
(Rs. In lakhs)
- 30% on Rs. 2 lakh 0.600
- 10% on Rs. 2 lakh u/s 115BBDA 0.200
Total 0.800
Add: Education Cess @ 3% 0.024
Total Tax Liability 0.824

Notes:
1) Dividend received by LLP from domestic companies in excess of Rs. 10 lakh would be
taxable u/s 115BBDA @ 10% as per FA 2017.
2) Successor to business will be allowed deduction of bad debts for debtors of
predecessor if it formed part of predecessor’s income.
3) Rs. 10 lakh incurred towards replacement of existing ceiling is a capital expense as it
increases the future benefits of the existing asset which has an enduring benefit as per
ICDS V. The amount shall be capitalised.
4) Conversion of interest into loan by bank cannot be considered as actual payment of
interest. Therefore, such amount shall be allowed as deduction only on actual
payment of loan instalment.
5) As per section 43B, any tax, duty, cess or fee is allowed as deduction on actual
payment. Furnishing of bank guarantee shall not mean actual payment.
6) Capital Gains on distribution of land on retirement of partner would be taxable in the
hands of firm u/s 45(4). FMV of the asset as on the date of distribution shall be the full
value of consideration as per section 45(4).
Capital Gains:
FVC u/s 45(4) - Rs. 90 lakh
(-) ICOA (50L x 272/100) - Rs. 136 lakh
Long Term Capital Loss - Rs. 46 lakh
Since Sec. 45(4) itself provides for the value on which the charge shall be created, it
shall override the valuation provision u/s 50C.
7) Conversion of Pvt. Ltd. Co. to LLP would be exempt u/s 47 as all the conditions are
satisfied. Other points arising on such conversion:
a) UAD of Pvt. Ltd. would be carried forward by successor LLP.
b) Business loss of A Pvt. Ltd. shall be carried forward by successor LLP for fresh
period of 8 years. However, since partner A retired during the year, his share of
loss would not be allowed to be carried forward as per section 78(1). Section 78(1)
shall not apply to UAD. Therefore, business loss that would not be carried forward
= Rs. 10 lakh x 1/3 = Rs. 3.33 lakh
 ∴ Rs. 6.67 would only be carried forward.
c) Speculative loss of A Pvt. Ltd. shall not be carried forward by LLP.
d) MAT credit shall lapse.
e) VRS exps. Of Rs. 5 lakh can be claimed by LLP during current year and remaining in
future years.
8) Depreciation:
Depreciation shall be allowed to successor LLP and Pvt. Ltd. co. based on
proportionate no. of days.
I) In hands of Company:
Plant and Machinery Building
WDV 60 lakh 20 lakh
Total 60 lakh 20 lakh
Depreciation Rate 15% 10%
Depreciation 9 lakh 2 lakh
No. of days 122 122
∴ Depreciation to Co. 3,00,822 0.66 lakh
(9 x 122/365) (2x122/365)
II) In hands of LLP:
No. of days 243 243
∴ Depreciation to LLP 5,99,178 1.34 lakh
Total Depreciation = Rs. 7.34 lakh

b) A Ltd. an Indian Company, gives following data. Find out tax payable for the Assessment year 2018-
19 and the amount of MAT credit.
Rs.in crore
Tax Payable under normal provisions (ignoring section 115JAA) (a) 1
Tax Payable under section 115JAA (b) 50
Tax Paid in a foreign country (which is otherwise eligible for claiming as (c) 45
tax credit under section 90/90A/91)
[4 Marks]
Solution:
Computation of MAT Credit and Tax Payable
Particulars Rs.in
crore
Tax Payable under normal provisions (ignoring section 115JAA) (a) 1
Tax Payable under section 115JAA (b) 50
Tax Paid in a foreign country (which is otherwise eligible for claiming as tax credit (c) 45
under section 90/90A/91)
Tax Payable before foreign tax credit [(a) or (b), whichever is higher ] (d) 50
Less : Foreign tax credit (c) (e) 45
Tax payable for the assessment year 2018-19 [(d) –(e)] (f) 5
MAT credit (before amendment) [excess of (b) over (a) ] (g) 49
Recalculation of MAT credit (after amendment )(i.e. ignore MAT provisions and
find out how much foreign tax credit is available) -
- Tax payable under normal provisions (a) (h) 1
- Foreign tax credit is utilized to pay MAT [(a) or (c), whichever is lower] (i) 1
- How much foreign tax credit is utilized to pay MAT (e) (j) 45
- Extra foreign tax credit utilized only because of MAT provisions [(j)-(i)] (k) 44
MAT credit (after amendment) to be carried forward to next 15 years [(g)-(k)] (l) 5
 Do go through MTP 1, MTP 2, Additional questions set very carefully. These
are most expected question sets for Nov., 18 attempt.
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