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CA FINAL (May 2024)

GROUP II – PAPER 4
DIRECT TAX LAWS & INTERNATIONAL TAXATION
(Series 1)
Time Allowed: - 3 Hours Maximum Marks: 100

This question paper comprises two parts, Part I and Part II.
Part I comprises MCQ & Part II comprises questions which require descriptive answers.
All questions relate to A.Y. 2024-25 unless stated otherwise in the question.

PART – I (MCQs)
All MCQs are compulsory

Question no. 1-15 carry 2 marks each

This Case Scenario contains MCQ 1-5

M/s. Yamuna Ltd., an unlisted public company, is in the business of growing rubber. The profit & loss
account for the year ended 31.03.2024 of the company shows a net profit ₹ 37.65 crores after debiting
depreciation of ₹ 30 crores.
The company has provided the following additional information:
(i) The company has deposited ₹ 30 crores in a special account with NABARD on 29.04.2024.
(ii) The company has brought forward losses of ₹ 6 crores pertaining to Assessment Year 2022-23.
Mr. A who continuously held 60% of shares carrying voting power since incorporation of the
company, had sold his entire holding to Mr. B on 01.08.2023.
(iii) The company had an accumulated balance of ₹ 200 crores in the special account with NABARD as
on 01.04.2023. It has withdrawn ₹ 40 crores and utilized the same for following purposes:
 Purchase of a new sprinkling machine for use in its operation ₹ 10 crores,
 Purchase of office appliances for corporate office at Chennai ₹ 10 crores.
 Purchase of computers and accessories ₹ 5 crores.
 Construction of a godown at a cost of ₹ 1 crore near the rubber estate to store raw rubber.
 Repairs to machinery ₹ 35 lakhs.
(iv) On 31.03.2024, the company has sold machinery which was purchased on 10.05.2020 for ₹ 10
crores. The purchase of the said machinery was in accordance with the scheme of deposit.
(v) Depreciation allowable as per Tax Audit Report is ₹ 28 crores.
You are required to answer the following:
1. What is the amount of deduction available under section 33AB for A.Y. 2024-25?
(a) ₹ 30,00,00,000
(b) ₹ 15,06,00,000

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 (c) ₹ 39,65,00,000
(d) ₹ 15,86,00,000
2. Compute Agricultural Income of Yamuna Ltd. for A.Y. 2024-25.
(a) ₹ 57,44,00,000
(b) ₹ 37,33,60,000
(c) ₹ 20,10,40,000
(d) ₹ 34,46,40,000
3. Compute Amount of brought forward losses pertaining to Assessment Year 2022-23 that
can be set-off from Business of A.Y. 2024-25.
(a) ₹ 6,00,00,000
(b) ₹ 3,60,00,000
(c) ₹ 2,40,00,000
(d) None of the Above
4. Compute Amount deemed as profits and gains of business or profession due to
misutilisation/non-utilisation of amount withdrawn from NABARD A/c.
(a) ₹ 23,65,00,000
(b) ₹ 10,00,00,000
(c) ₹ 33,65,00,000
(d) ₹ 13,65,00,000
5. Compute Taxable Income of M/s. Yamuna Ltd. for A.Y. 2024-25.
(a) ₹ 14,10,40,000
(b) ₹ 57,44,00,000
(c) ₹ 20,10,40,000
(d) ₹ 37,33,60,000

This Case Scenario contains MCQ 6-11

Mr. Jonny (person of Indian origin) whose age is 68 years returned to India on 3rd October, 2023 at
12:00 A.M. for permanently residing in India after a stay of about 10 years in U.S., provides the
sources of his various income and seeks your opinion to know about his liability to income tax
thereon in India in assessment year 2024-25. He is also resident of US in Previous Year 2023-24 as
per US Tax Law. Assume there is no double taxation avoidance agreement between India and US. Also
assume that Mr. Jonny has exercised the option to opt out of the default tax regime u/s 115BAC.
Details of Income earned by Mr. Jonny in Previous Year 2023-24 is as under:
Particulars ₹
(a) Profits from a business in Ranchi managed from US 1,23,000
(b) Income from property in US received there 36,000
(c) Income from agricultural land in Nepal received there and remitted to India later on. 33,500
(d) Interest on debentures in an Indian company received in US 6,200
(e) Income from profession in US which was set up in Patna, received there. 42,000
(f) Profits earned from business in US which is controlled from Jamshedpur, 25% of the 80,000
profits being received in Jamshedpur
(g) Fees for technical services rendered in Patna (connected with PE in India) but 1,25,000

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 received in US
(h) Untaxed Income from US of earlier years brought to India 15,500
(i) Dividend from a US company received in US 14,000
(j) Interest on development bonds issued in US, 40% of interest received in Patna 20,000

In the light of above facts, you are required to answer the following:
6. What would be the residential status of Mr. Jonny in A.Y. 2024-25 -
(a) Resident and Ordinary Resident
(b) Resident but Not Ordinary Resident
(c) Non-Resident
(d) Non-Resident Indian
7. Compute Total Income of Mr. Jonny for the A.Y. 2024-25 -
(a) ₹ 4,79,700
(b) ₹ 3,84,200
(c) ₹ 2,82,200
(d) ₹ 2,97,700
8. Compute the Tax Liability (Before providing relief u/s 87A) of Mr. Jonny for the A.Y.
2024-25 -
(a) ₹ 1,674
(b) ₹ 4,378
(c) ₹ 9,344
(d) Nil
9. Compute the relief available to Mr. Jonny for the A.Y. 2024-25 u/s 91 -
(a) ₹ 4,378
(b) Nil
(c) ₹ 1,674
(d) ₹ 9,344
10. Fees for technical service earned by Mr. Jonny in India is taxable at _____ rate in A.Y. 2024-
25 -
(a) 10%
(b) 20%
(c) Slab Rate
(d) Not Taxable
11. Assume there is Double Taxation Avoidance Agreement between India and US, then as
per Article 4 of DTAA, Mr. Jonny will be treated as Resident of which country in A.Y.
2024-25 -
(a) US
(b) India
(c) Both US and India
(d) Neither India nor US

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This Case Scenario contains MCQ 12-15
Prakash, a member in two AOPs, namely, “AOP & Co.” and “Prakash & Akash”, provides the following
details of his income for the year ended 31.3.2024:
(i) “AOP & Co.”, assessed at normal rates of tax, had credited in his account, amount of ₹ 2,10,000
as interest on capital, ₹ 4,96,000 as salary and ₹ 20,000 as share of profit.
(ii) A house property located at Jaipur was purchased on 1.7.2014 with the borrowed capital in
“Prakash & Akash” jointly shared equally and occupied by both of them for self-residential
purposes. Total interest paid for the year 2023-24 on the borrowed capital was ₹ 4,10,000.
(iii) Mr. Prakash has exercised the option to shift out of the default tax regime u/s 115BAC.
From the details given above, choose the most appropriate option to the questions given below:
12. What would be the amount of deduction available to Mr. Prakash under section 24 in
respect of interest on borrowed capital for A.Y. 2024-25-
(a) ₹ 1,00,000
(b) ₹ 2,00,000
(c) ₹ 2,05,000
(d) Nil
13. Compute Total Income of Mr. Prakash for the A.Y. 2024-25 -
(a) ₹ 5,26,000
(b) ₹ 7,26,000
(c) ₹ 6,26,000
(d) ₹ Nil
14. Compute the loss from house property for A.Y. 2024-25 that can be carry forward by Mr.
Akash to A.Y. 2025-26 -
(a) ₹ 2,05,000
(b) ₹ Nil
(c) ₹ 1,00,000
(d) ₹ 2,00,000
15. Compute the rebate available to Mr. Prakash under section 86 for the A.Y. 2024-25 -
(a) ₹ 25,410
(b) ₹ 18,408
(c) ₹ 17,700
(d) ₹ Nil

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 PART – II (Descriptive Answers)
This part comprises 6 questions. Question No. 1 is compulsory. Attempt any
4 questions out of the remaining 5 questions.

1 SF Ltd. is engaged in manufacturing and sale of pharmaceutical products. The net 14

profit of the company as per statement of profit and loss for the year ended 31 st
March, 2024 is ₹ 930 lakhs, after debiting or crediting the following items:
(i) The opening and closing stock for the year were ₹ 66 lakhs and ₹ 63 lakhs
respectively. Opening stock was overvalued by 10% and Closing stock was
undervalued by 10%.
(ii) Payment of ₹ 65 lakhs on 15th October 2023 to a foreign company for
obtaining know how for a product launched in the month of November
2023.
(iii) Profit on sale of 2200 shares of M/s. MS Ltd., a listed company ₹ 2,97,000.
These shares were sold on 27.11.2023 for ₹ 220 per share. The highest price
of MS Ltd. quoted on the stock exchange as on 31.01.2018 was ₹ 195 per
share. The said shares were acquired for ₹ 85 per share on 12.08.2017. STT
was paid both at the time of purchase and sale of shares.
(iv) Electricity charges of ₹ 8 lakhs for the month of February 2024 and March
2024 was unpaid up to the due date of filing of return.
(v) Loss of ₹ 2.2 lakhs due to hedging contract against future price fluctuations
in respect of import of raw material, used in the course of manufacturing.
(vi) Depreciation charged to the Statement of Profit and Loss was ₹ 48 lakhs.
(vii) Credits to statement of Profit and Loss include dividend of ₹ 5,20,000
received from a foreign company, in which it holds 30% voting rights.
(viii) ₹ 32 lakhs received from Zen Ltd. under an agreement in the form of non-
compete fees for not carrying out any business in a particular product.
(ix) Advance received amounting to ₹ 22 lakhs on proposed sale of land,
forfeited due to non-receipt of balance amount of ₹ 70 lakhs on time, as per
terms of agreement. The land was purchased during FY 2020-21.
(x) Excess on sale of unlisted shares - ₹ 18 lakhs (Sold on 18th January 2024).
(xi) Loss of ₹ 2 lakh from hedging contracts entered into for mitigating the loss
arising due to fluctuation in foreign currency payment towards an imported
machinery purchased from Japan for ₹ 70 lakhs, which was installed and put
to use in the month of November 2023.
Additional Information:
(1) Normal depreciation allowable as per the Income-tax Act, 1961 ₹ 35 lakhs.
(2) Depreciation on plant and machinery imported and installed during
November 2023 and on technical know-how has not been considered while
calculating normal depreciation as per Income-tax Act, 1961 given in (1)
above.
(3) During the year F.Y. 2023-24, the company has employed 59 additional
employees. All these employees contribute to a recognized provident fund.
36 out of 59 employees joined on 1.6.2023 on a salary of ₹ 15,000 per

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 month, 18 joined on 1.7.2023 on a salary of ₹ 35,200 per month, and 5
joined on 1.11.2023 on a salary of ₹ 22,000 per month. The salaries of 10
employees who joined on 1.6.2023 are being settled by bearer cheques
every month. Audit under section 44AB has been done before the due date.
(4) The unlisted shares were acquired on 18.2.2021 for ₹ 80 lakhs.
(5) Cost Inflation Index F.Y. 2020-21 - 301, F.Y. 2023-24- 348.
You are required to compute the total income and tax liability of the company for
the A.Y.2023-24 clearly stating the reasons for treatment of each of the items
given above. The return of income of the company is to be filed applying the
provisions of section 115BAA.

2 (a) M/s ABC LLP is engaged in export of computer software from a Special Economic 8
Zone. The net profit of the firm as per its Profit & Loss Account for the year ended
31.3.2024 was ₹ 250 lakhs after debit/credit of the following items:
(1) Depreciation ₹ 20 lakhs
(2) Remuneration to its working partners ₹ 200 lakhs
(3) Interest provided on the current account balance of the partners @ 15% p.a.
₹ 15 lakhs
(4) Advertisement in a souvenir published by a political party ₹ 2 lakhs
Additional Information:
(1) The firm commenced business on 1.4.2019.
(2) Depreciation allowable as per Income-tax Rules is ₹ 25 lakhs.
(3) Payment of remuneration to working partners is authorized by the
Partnership Deed. However Interest is not authorised by Deed.
(4) Brought forward business loss and depreciation from Assessment Year
2023-24 was ₹ 50 lakhs and ₹ 30 lakhs respectively.
(5) The total & export turnover of the firm was ₹ 25 crores. Amount of export
turnover realized within six months was ₹ 25 crores.
Compute the tax payable by the firm under section 115JC and the amount of tax
credit allowed to be carried forward. Give working notes for your answer.

2 (b) Mr. S is a performing musician, resident of India. He has following income for year 6
ended 31.3.2024.
(1) Income from music performances in India ₹ 5,00,000.
(2) Income from Country A with which India does not have any Double
Taxation Avoidance Agreement ₹ 5,00,000. Tax deducted from this income
was at 20%.
(3) Income from Country B during January 2023 ₹ 1,00,000, July 2023 ₹
1,00,000 and January 2024 ₹ 3,00,000.
Tax withheld by Country B is at 10%.
Country B follows Calendar Year for its tax purposes. India has entered into
a Double Taxation Avoidance Agreement with Country B.

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 (4) Rent received from his property at Chennai ₹ 30,000 per month.
(5) Contribution to PPF is ₹ 1,50,000.
Compute tax payable by Mr. S for the Assessment Year 2024-25, assuming that he
opted out of the default tax regime under section 115BAC.

3 (a) Mathi Charitable Trust registered under section 12AB, following cash system of 8
accounting, furnishes you the following information:
(i) Gross receipts from hospital by name "Full Cure" ₹ 400 lakhs.
(ii) Gross receipts from college by name "India Arts College ₹ 180 lakhs.
(iii) Corpus donations by way of cheque ₹ 30 lakhs and by way of cash ₹ 5 lakhs.
The corpus donation is invested in modes specified under section 11(5).
(iv) Anonymous donations by cash ₹ 10 lakhs.
(v) Administrative expenses for hospital ₹ 220 lakhs and for college ₹ 100
lakhs.
(vi) Fees not realized from patients ₹ 20,60,000 and from students of the college
₹ 6,50,000 as on 31st March, 2024.
(vii) Depreciation on assets of the trust ₹ 18,00,000. The entire cost of assets ₹
300 lakhs claimed as application in the earlier years.
(viii) Acquired a building for ₹ 120 lakhs for expansion of hospital (cost of land
included therein ₹ 100 lakhs). Stamp duty value of the land and building on
the date of registration of sale deed ₹ 140 lakhs.
(ix) The trust gave donation of ₹ 25 lakhs to Gandhiji Trust having objects of
charitable nature registered under section 12AB but not similar to the
objects of the donor trust.
You are required to compute the total income of the trust and its income-tax
liability in such a manner that it can avail the optimal benefit within the four
corners of the Income-Tax Act, 1961 assuming trust has not opted for Section
115BAC.
Note: The trust does not want to seek accumulation of income by virtue of section
11(2) of the Act.

3 (b) State with brief reasons, which method of determination of ALP will be most 6
appropriate in the following cases:
(i) A Co. Ltd., Mumbai is engaged in manufacture of garments. It manufactured
and supplied as per the variation and customization in finishing of products
to its associated enterprises Xylo Inc. UK as compared to the goods regularly
sold to third parties.
(ii) DEF Co. Ltd., is engaged in manufacture of medicines. It manufactured semi-
finished drugs in bulk and sold to related parties located in India and
outside India. It adds gross profit mark up on direct and indirect costs of
production.
(iii) ZY Ltd., Bengaluru provided identical call centre services to both related
and unrelated parties.

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4 (a) Examine the applicability of provisions relating to deduction of tax at source and 8
compute the liability, if any, for deduction of tax at source in the following cases:
(i) In terms of agreement between A (the Owner of land) and B (Developer and
Builder) the Developer, B agrees to allot 5 apartments to the owner in part
consideration for providing his land and also agreed to pay a sum of ₹
25,00,000. In terms of the agreement, Mr. B issued a cheque for ₹ 25,00,000
towards money consideration on 30.03.2024.
(ii) Rent of ₹ 60,000 per month deposited by Mr. Shrikanth, software employee
on 1st of every month in advance, in the account of Mr. Ashok, who does not
provide his PAN. The house was taken on rent with effect from 01.07.2023
and he vacated the house on 28.02.2024.
Would there be any change in TDS, if Mr. Ashok furnished his PAN to the
tenant?
(iii) Param Construction Ltd. sells a flat to Mr. Mani for ₹ 48 Lakhs (SDV ₹ 40
Lakhs). The agreement to sell provides that in addition, Mr. Mani has to pay
maintenance charges (of ₹ 5,000 per month) for 24 months in advance ₹
2,00,000 for car parking to be used exclusively by him and ₹ 1,00,000 for
club membership fees to Param Construction Ltd. before the flat is
registered in the name of Mr. Mani.
(iv) ₹ 19,50,000 credited to the account of Digitec Studios (a partnership firm)
by B-TV, Television channel, towards part consideration for shooting of Tele
Episode for 10 weeks as per the storyline, contents and specifications of B-
TV channel.

4 (b) Simran (P) Ltd. holds 55% of shares in Al Kuber Ltd., a Company incorporated in 6
Dubai. Al Kuber Ltd. has its offices in India also.
Details relating to Al Kuber Ltd. for year ended March 2024 are as stated below: (₹ in crores)
Particulars India Dubai
• Fixed Assets after considering Depreciation for tax 1500 650
purposes
• Intangible Assets 225 1075
• Other Assets (value as per books of A/c) 800 1900
• Income from trading operations. The above figure 730 1370
includes:
a. Income from transactions where sales are to AE 20 40
b. Income from transactions where purchases are 30 55
from AE
c. Income from transactions where 45 80
sales/purchases are to/from AE
• Interest & Dividend from investments 560 320
• No. of employees 70 90
 Unskilled employees out of the above mentioned 5 30

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 total employees (resident in respective
countries)
• Payroll expenses on employees 940 1250
 Payroll expenses on Unskilled employees out of 100 415
the above mentioned total Payroll expenses
• No. of Board Meetings held 3 4

Determine the Residential Status of Al Kuber Ltd. for A.Y. 2024-25.

5 (a) (i) Mr. Sanskar is engaged in the business of retail trade and has been 8
declaring income of ₹ 10 lakhs to ₹ 15 lakhs every year in the last 10 years.
A search was conducted under section 132 in the business premises of
Sanskar on 5th December, 2023. The search was concluded by executing last
of authorisation for search on 21st December, 2023. The A.O. has in his
possession documents which revealed that Mr. Sanskar has incurred ₹ 5
crores in May 2017 for the marriage of his daughter. The A.O intends to
issue notice under section 148 to Sanskar for the Assessment Year relevant
to the previous year 2017-18. Can he do so?
(ii) “The arm’s length price (ALP) determined by the Tribunal, which is the final
fact-finding authority, is final and cannot be the subject matter of scrutiny
by the High Court as it does not give rise to a substantial question of law;
accordingly, in an appeal u/s 260A, the High Court is precluded from
examining the correctness of determination of the ALP” – Examine the
correctness of this statement.

5 (b) Spacecraft Ltd., an Indian company, has entered into a contract for ₹ 4.5 crores 6
with DOT Inc., Country X for the Financial Year 2023-24. DOT Inc. maintains an
online web-platform through which it provides end user computer software
through an End-user Licence Agreement (EULA) as per the contract. The broad
terms of the EULA between the two companies are as follows-
Grant of licence. DOT Inc. grants Spacecraft Ltd. a limited non-exclusive licence to
install, use, access, display and run the click wrap web-based Computer Software
(CWCS) on a single local hard disk(s) or other permanent storage media of one
computer. Spacecraft Ltd. should not make CWCS available over a network where
it could be used by multiple computers at the same time.
Reservation of rights and ownership. DOT Inc. reserves all rights not expressly
granted to Spacecraft Ltd. in this EULA. The CWCS is protected by copyright and
other intellectual property laws and treaties. DOT Inc. owns the title, copyright
and other intellectual property rights in the CWCS. The CWCS is licenced (only for
use and not any other purpose), not sold.
DOT Inc. does not have any offices outside Country X.
Discuss the tax implications/TDS implications of such receipt in the hands of DOT
Inc., Country X and payment by Spacecraft Ltd., India under Chapter VIII of the
Finance Act, 2016 and Income-tax Act, 1961, considering the India-Country X
DTAA also, the relevant extract of which is given hereunder:

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 Extract of Article 12 of India-Country X DTAA Royalties and Fees for Technical
Services
1. Royalties and fees for technical services arising in a Contracting State and
paid to a resident of the other Contracting State may be taxed in that other
State.
2. However, such royalties and fees for technical services may also be taxed in
the Contracting State in which they arise and according to the laws of that
Contracting State, but if the recipient is the beneficial owner of the royalties
or fees for technical services, the tax so charged shall not exceed 10 per
cent.
3. The term "royalties" as used in this Article means payments of any kind
received as a consideration for the use of, or the right to use :
(a) any copyright of a literary, artistic or scientific work, including
cinematograph film or films or tapes used for radio or television
broadcasting, any patent, trademark, design or model, plan, secret
formula or process, or for information concerning industrial,
commercial or scientific experience, including gains derived from the
alienation of any such right, property or information

6 (a) Siddharth Garments Ltd, a company incorporated under The Companies Act, 2013 6
having factory and registered office in Mumbai engaged in the manufacturing of
Men’s wear, and selling various kinds of garment products according to the
requirement of the buyers across the world. The company sold different garment
products in the financial year 2023-24 different vendors as detailed under:
Product Type Trouser T-Shirt Office Wear Formal
Shirt Shirt
Sold to the Vendor Polo Inc. Oxfam Pty. John Miller John Player
Pty (US UK
based Co.) (Subsidiary of
the Indian
Co.)
Price Charged ₹ 1,400 ₹ 1,000 ₹ 1,200 ₹ 1,500
Quantity Sold 200,000 250, 000 pcs. 150, 000 pcs. 190, 000 pcs.
pcs.

Siddharth Garments Ltd. maintains a gross profit margin of 30% on the selling
price. Siddharth Garments Ltd has purchased the T-Shirts sold to its UK based
subsidiary Oxfam Pty of UK from Mudra Garments Ltd, of Ahmedabad at per piece
price of ₹ 840/-.
Following functional differences were noticed between the transactions with
Oxfam Pty of UK and other parties:
(i) Sales to non-associated party have been made with a specialized packaging
for which 3% margin is included in the selling price.
(ii) Tagging on the product purchased is being required by the other clients of
which cost was ₹ 3 per piece whereas in case of sales made to Oxfam Pty of
UK no tagging is to be done.

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 (iii) Products sold to non-associated parties involve a credit period of 6 months
for which 0.5% per month margin on selling price is ensured by Siddharth
Garments Ltd.
Determine the arm’s length price based on the above information.

6 (b) Deepak, aged 45 (an Indian citizen) has settled in California, USA since 2015. Prior 4
to that, he has always been in India. He had acquired a residential property in
California on 25.06.2009 for USD 20,000. He kept bank deposit of USD 10,000 in a
bank account in New York since 15.04.2010.
Notice under Black Money (Undisclosed Foreign Income and Assets) and
Imposition of Tax Act, 2015 was issued on 20.10.2023. The fair market value of
residential property as on 01.04.2023 was USD 25,000; on 01.04.2024 USD 32,000
and 20.10.2023 USD 30,000. The bank deposit with accrued interest thereon was
USD 12,500 on 01.04.2023; USD 12,800 on 01.04.2024 and USD 12,700 on
20.10.2023.
Note: USD = United States Dollar
The exchange rate of Indian currency per 1 USD as per the reference rate of the
RBI on the various dates are:
01.04.2023 = ₹ 71
20.10.2023 = ₹ 72
01.04.2024 = ₹ 73
Compute the value of undisclosed foreign asset chargeable to tax in the hands of
Deepak as per Black Money (Undisclosed Foreign Income and Assets) and
Imposition of Tax Act, 2015.

6 (c) XYZ & Co, a firm engaged in interior decoration business, employed 20 new 4
employees on 1.4.2023 on a monthly salary of ₹ 25,000 to be paid by account
payee cheque. In addition, each employee was entitled to 10% employer
contribution to recognised provident fund. The employees were also entitled to
transport allowance of ₹ 3,000 p.m. paid in cash. The gross total income of XYZ &
Co. included profits and gains from business of ₹ 62 lakh.
The firm claimed deduction under section 80JJAA of ₹ 18 lakh, being 30% of 60
lakh (20 new employees x ₹ 25,000 p.m. x 12) on the basis of the report of the
chartered accountant issued in Form 10DA. The same chartered accountant was
also the tax auditor of the firm. The chartered accountant contended that
“emoluments” do not include employer contribution to PF. Also, cash payments
were not to be considered as “additional employee cost” for the purpose of section
80JJAA. Hence, only ₹ 25,000 p.m. per employee paid by account payee cheque has
to be treated as additional employee cost. Since the same does not exceed the limit
of ₹ 25,000 p.m. and the employees have been employed for more than 240 days
in the P.Y.2023-24, the employees would qualify as “additional employees” for the
purpose of deduction under section 80JJAA for A.Y.2024-25.
Is his contention correct? Examine the ethical implications in this case.

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