Q.4 ICAI Taxation question paper solution of nov 2020 by CS K K Agrawal
Question 4 (a) Mr. Thomas, a non-resident and citizen of Japan entered into following transactions during the previous year ended 31.03.2020. Examine the tax implications in the hands of Mr. Thomas for the Assessment Year 2020-21 as per Income Tax Act, 1961. (Give brief reasoning) (1) Interest received from Mr. Marshal, a non-resident outside India (The borrowed fund is used by Mr. Marshal for investing in Indian company’s debt fund for earning interest). S 9(1)(v)-Income accrues in India (2) Received ₹ 10 lakhs in Japan from a business enterprise in India for granting license for computer software (not hardware specific). Proviso to S 9. Income do not accrue in India (3) He is also engaged in the business of running news agency and earned income of ₹ 10 lakhs from collection of news and views in India for transmission outside India. Explanation to S 9. Income do not accrue in India (4) He entered into an agreement with SKK & Co., a partnership firm for transfer of technical docum...