Paper - 4: Taxation Section A: Income Tax Law Part - II: Receipts Payments

PAPER – 4 : TAXATION
SECTION A : INCOME TAX LAW

Part - II
Question No.1 is compulsory.
Candidates are also required to answer any two questions from the remaining three
questions.
Working notes should form part of the respective answers. All questions relate to assessment
year 2022-23, unless otherwise stated.
Question 1
Dr. Rohan, 82 years old resident surgeon, having his Nursing Home in Mumbai, gives the
following particulars for the year ended on 31.03.2022.
Receipts ` Payments `
Opening Balance b/d 1,25,000 Salary to Staff 3,50,000
Fees from visits to other 5,85,000 Taxes & Insurance 26,000
hospitals (net)
Fees for March, 2021 received in Entertainment Expenses 1,10,000
April, 2021
IPD 40,000 85,000 Purchase of Television 48,000
OPD 45,000
Dividend from shares (net) 18,900 Gift to daughter-in law 60,000
Fees received during the year 10,25,000 Interest on loan for repairs to 65,000
property
Gifts received from relatives of 45,000 Personal medical expenses 70,000
patients
Honorarium for painting services 22,500 Deposits in PPF A/c 55,000
in Jai Hind Art School (net)
Income-tax Refund (Including 12,100 Nursing Home expenses 3,75,000
interest ` 1,500)
Prof. fees paid for consulting 1,20,000
services
The Suggested Answers for Paper 4A: Income-tax Law are based on the provisions of Income-
tax Act as amended by the Finance Act, 2021 which are relevant for November, 2022
Examination. The relevant assessment year is A.Y.2022-23.
© The Institute of Chartered Accountants of India

2 INTERMEDIATE EXAMINATION: NOVEMBER, 2022
Purchase of furniture at 1,35,000

home
Personal Expenses 3,00,000
Balance c/f 2,04,500
19,18,500 19,18,500
Other Information:
(a) He keeps his books of accounts on cash basis and has not opted for the provisions of
section 44ADA.
(b) Salary includes ` 60,000 paid to his sister who is a qualified nurse paid in cash.
(c) Entertainment expenses include ` 25,000 for dinner to doctors in a five star hotel.
(d) Interest on loan for repairs to property includes ` 40,000 for his residential property.
(e) His daughter in law earned income of ` 10,000 from the amount received as gift.
(f) Fixed Assets values as on 01.04.2021 are as under :
Nursing Home Equipment's ` 2,20,000, Medical Books (incl. annual publications ` 10,000)
` 35,000, Laptop ` 40,000.
(g) Television purchased for nursing home purpose on 21.09.2021 is put to use on 03.10.2021.
(h) He has donated ` 10,000 towards PM CARES Fund on 15.08.2021.
You are required to
(i) Compute the total income and tax payable by him for AY 2022-23 as per the regular
provisions of the Income-tax Act, 1961. Assume that he has not opted for section 115BAC.
(ii) What will be his total income and tax payable, if he opts for the provisions of section
44ADA? Will it be more beneficial for him to adopt 44ADA? (14 Marks)
Answer
(i) Computation of total income and tax payable by Dr. Rohan for A.Y. 2022-23 as per
the regular provisions of the Act
Particulars ` ` `
I Income from house property
Annual value [Assuming residential property is Nil
self-occupied]
Less: Deduction under section 24(b)
Interest on loan for repairs to property, 30,000
` 40,000, restricted to

PAPER – 4 : TAXATION 3
Loss from self-occupied property (30,000)

[can be set-off against Profits and gains of
business or profession or Income from other
sources]
II Profits and gains from business and
profession
Gross Receipts
Fees from visits to other hospitals 6,50,000
[5,85,000/90%]
Fees for March 2021 received in April 2021 85,000
[Fees for March 2021 is chargeable to tax
during P.Y. 2021-22, since Dr. Rohan is
following cash system of accounting] [40,000 +
45,000]
Fees received during the year 10,25,000
Gifts received from relatives of patients
[taxable as business income] 45,000 18,05,000
Less: Permissible deductions
Salary to staff [Salary paid to his sister who is 2,90,000
a qualified nurse in cash disallowed under
section 40A(3), since such cash payment
exceeds ` 10,000] [` 3,50,000 – ` 60,000]
Taxes and insurance 26,000
Entertainment expenses, including dinner to 1,10,000
doctors [Assuming that the entire sum was
incurred wholly and exclusively for business
purpose]
Interest on loan for repair to property [to the 25,000
extent relating to business] = ` 65,000 –
` 40,000, relating to residential property
Nursing home expenses 3,75,000
Professional fees paid for consulting services 1,20,000 9,46,000
8,59,000
Less: Depreciation under section 32
Nursing home equipment’s [2,20,000 x 15%] 33,000
Note – Nursing home equipment would be
eligible for depreciation @15%, being the

general rate for plant and machinery. The main

solution has, accordingly, been worked out
applying 15%. However, if such equipment are
in the nature of life saving medical equipment,
they would be eligible for higher depreciation
@40%. If 40% rate is applied, depreciation would
be ` 88,000
Medical books [35,000 x 40%] 14,000
Laptop [40,000 x 40%] 16,000
Television [48,000 x 15%, since the television 7,200 70,200
is put to use for 180 days during the P.Y.
2021-22]
Note - Television would be eligible for
depreciation @15%. However, television
connected to laptop or other medical
equipment and used by Doctor may be
classified as plant and machinery eligible for
depreciation @40%. If 40% rate is applied,
depreciation for TV would be ` 19,200.
Also, it is possible to take a view that Television 7,88,800
is furniture and fixtures qualifying for
depreciation@10%. If 10% rate is applied,
depreciation for TV would be ` 4,800.
III Income from Other Sources
Dividend from shares [18,900/90%] 21,000
Honorarium for painting services in Jai Hind Art 25,000
School [22,500/90%]
Honorarium (Alternative without TDS) -
` 22,500
Note – In the question, it is mentioned that
Dr. Rohan has received Honorarium for
painting services in Jai Hind Art School (Net) of
` 22,500. Since the threshold limit for
deducting tax at source under section 194J is
` 30,000, there is no requirement to deduct tax
at source on such income. Accordingly,
question can be answered without grossing up
the amount of honorarium of ` 22,500.
Interest on income-tax refund 1,500

Income earned from gift to daughter in law

[Income earned by daughter in law from asset
gifted without consideration to her by
Dr. Rohan is includible in the hands of
10,000 57,500
Dr. Rohan]
Gross Total Income 8,16,300
Less: Deduction under Chapter VI-A
Deduction under section 80C
Deposits in PPF 55,000
Deduction under section 80D
Medical expenses to the extent of 50,000
` 50,000 since Dr. Rohan is a senior
citizen (assuming he has not taken any
medical insurance policy)
Deduction under section 80G
Donation towards PM CARES Fund 10,000 1,15,000
Total Income 7,01,300
Tax Payable
Upto ` 5,00,000 [since Dr. Rohan is aged 80 Nil
years or above]
` 5,00,001 to ` 7,01,300 [` 2,01,300@20%] 40,260
40,260
Add: HEC@4% 1,610
Tax liability 41,870
Less: TDS on fees from visits to other hospitals 65,000
TDS on dividend from shares 2,100
TDS on honorarium for painting services 2,500 69,600
in Jai Hind art School
Tax Refundable 27,730
(ii) Computation of total income and tax payable by Dr. Rohan for A.Y. 2022-23 if he opts
for section 44ADA
Particulars ` `
I Income from house property
Loss from self occupied property (30,000)
II Income from business or profession
Income from profession [18,05,000 x 50%] [No 9,02,500
other expenditure or depreciation is allowed]

III Income from Other Sources 57,500

Less: Deduction under Chapter VI-A 1,15,000
Total Income 8,15,000
Tax Payable
Upto ` 5,00,000 Nil
` 5,00,001 to ` 8,15,000 [3,15,000@20%] 63,000
63,000
Less: HEC@4% 2,520
Tax liability 65,520
Less: TDS 69,600
Tax Refundable 4,080
Since tax refundable in case Dr. Rohan opts for the provisions of section 44ADA
is lower than the regular provisions of the Act, it would be beneficial for him not to
opt for section 44ADA and get his books of account audited and declare income
under the regular provisions.
Question 2
(a) Mr. Sarthak, an individual and Indian citizen living abroad (Dubai), a tax haven, since year
2005 and never came to India for a single day since then, earned the following incomes
during previous year 2021-22:
Particulars Amount (in `)
(i) Income accrued and arisen in Dubai not taxable in Dubai 20,00,000
(being tax haven)
(ii) Income accrued and arisen in India 5,00,000
(iii) Income deemed to accrue and arise in India 8,00,000
(iv) Income arising in Dubai from a profession set up in India 10,00,000
I. Determine the residential status of Mr. Sarthak and taxable income for the previous
year 2021-22 (assuming no other income arise during the previous year).
II. What would be your answer if income arising in Dubai from a profession set up in
India is ` 2 lakhs instead of ` 10 lakhs?
III. What would be your answer, if Mr. Sarthak born in Dubai and his parents were born
in India? (6 Marks)

(b) Mr. B is a sales manager in PQR Ltd. During F.Y. 2021-22 he has received the following
towards his salary and allowances/perquisites;
(i) Basic pay ` 85,000 per month upto December 2021 and thereafter an increase of
` 2,000 per month.
(ii) Dearness allowance 40% of basic pay forming part of retirement benefits.
(iii) Bonus 1 month basic pay based on the salary drawn during January month every
year.
(iv) He contributes 14% of his basic pay & DA towards his recognized provident fund and
his employer company contributes the same amount.
(v) Travelling allowance of ` 5,000 per month towards on duty tours.
(vi) Research and training allowance ` 3,000 per month.
(vii) Children education allowance of ` 600 per month, per child for his 2 sons and 1
daughter.
(viii) Accommodation owned by PQR Ltd. was provided to him in Hyderabad for the whole
year and furniture of ` 2,00,000 was provided from 1 st October, 2021.
(ix) Reimbursement of medical expenses on his treatment in private hospital -` 15,000,
medical allowance ` 1,500 per month. Company has paid premium on medical policy
purchased on his health ` 12,500.
You are required to:
I. Compute the income chargeable to tax under the head "Income from Salary",
assuming that he does not opt for the provisions under section 115BAC.
II. What will be the income under the head “Salaries”, if he opts for the provisions under
section 115BAC? (8 Marks)
Answer
(a) I. Mr. Sarthak is an Indian citizen living in Dubai since 2005 who never came to India
for a single day since then, he would not be a resident in India for the P.Y. 2021 -22
on the basis of number of days of his stay in India as per section 6(1).
However, since he is an Indian citizen
− having total income (excluding income from foreign sources) of ` 23 lakhs,
which exceeds the threshold of ` 15 lakhs during the previous year; and
− not liable to tax in Dubai,
he would be deemed resident in India for the P.Y. 2021-22 by virtue of section 6(1A).

A deemed resident is always a resident but not ordinarily resident in India (RNOR).
Computation of Total Income for A.Y.2022-23
Particulars `
(i) Income accrued and arisen in Dubai (not taxable in case of an -
RNOR)
(ii) Income accrued and arisen in India (taxable) 5,00,000
(iii) Income deemed to accrue or arise in India (taxable) 8,00,000
(iv) Income arising in Dubai from a profession set up in India would
be taxable in case of RNOR 10,00,000
Total income 23,00,000
II. If income arising in Dubai from a profession set up in India is ` 2 lakhs instead of
` 10 lakhs, his total income (excluding income from foreign sources) would be only
` 15 lakhs. Since the same does not exceed the threshold limit of ` 15 lakhs, he
would not be deemed resident.
Accordingly, he would be non-resident in India for the P.Y. 2021-22 and hence, his
total income would be only ` 13 lakhs (aggregate of (ii) and (iii) above i.e., ` 5 lakhs
+ ` 8 lakhs).
III. If Mr. Sarthak is born in Dubai and his parents were born in India, he would not be an
Indian citizen, but he may qualify as person of Indian origin. In such case, the
provisions relating to deemed resident would not apply to him.
Accordingly, he would be non-resident in India during the P.Y. 2021-22 and his total
income would be `13 lakhs.
Note – In sub-part III., it is inferred that he is not a citizen of India since he is not
born in India. It is assumed that he has not applied for citizenship by fulfilling the
other specified eligibility conditions.
(b) I. Computation of income chargeable to tax under the head “Salaries” for
A.Y.2022-23, if Mr. B does not opt for the provisions of section 115BAC
Particulars ` `
Basic Pay [` 85,000 x 9 + ` 87,000 x 3] 10,26,000
Dearness Allowance [` 10,26,000 x 40%] 4,10,400
Bonus 87,000
Travelling allowance [Exempt, since provided towards -
duty tours1]
1 It is assumed that he has fully expended the amount

Research and training allowance [` 3,000 x 12] 36,000

Medical allowance [` 1500 x 12] 18,000
Children Education allowance [` 600 x 12 x 3] 21,600
Less: Exempt [`100 x 12 x 2] 2,400 19,200
Salary (for the purpose of valuation of Rent-free 15,96,600
accommodation)
Value of Rent-free accommodation [15% of 2,39,490
` 15,96,600]
Add: Value of furniture [` 2,00,000 × 10% p.a. for 6 10,000 2,49,490
months]
Reimbursement of medical expenses [taxable, since 15,000
amount is reimbursed for treatment in private hospital]
Health insurance premium paid by PQR Ltd. [Exempt] -
Employers’ contribution to RPF in excess of 12% of 28,728
salary = 2% of ` 14,36,400 (` 10,26,000 + ` 4,10,400)
Gross Salary 18,89,818
Less: Deductions under section 16
Standard deduction 50,000
Income chargeable under the head “Salaries” 18,39,818
II. Computation of income chargeable to tax under the head “Salaries” for
A.Y.2022-23, if Mr. B opts for the provisions of section 115BAC
Add: Exemption in respect of children education 2400
allowance [Not allowable as per section 115BAC]
Add: Standard deduction [Not allowable as per section 50,000
115BAC]
18,92,218
Less: Value of rent-free accommodation (As per 2,49,490
regular provisions)
16,42,728
Add: Value of Rent-free accommodation [15% of
` 15,99,000 (` 15,96,600 (as calculated above) +
` 2,400)] 2,39,850
Add: Value of furniture [` 2,00,000 × 10% p.a. for 6 2,49,850
months] 10,000

Question 3
(a) Examine the applicability and the amount of TDS to be deducted in the following cases for
F.Y. 2021-22:
(i) S and Co. Ltd. paid ` 25,000 to one of its Directors as sitting fees on 02-02-2022.
(ii) ` 2,20,000 paid to Mr. Mohan, a resident individual, on 28-02-2022 by the State of
Haryana on compulsory acquisition of his urban land.
(iii) Mr. Purushotham, a resident Indian, dealing in hardware goods has a turnover of
` 12 crores in the previous year 2020-21. He purchased goods from Mr. Agarwal a
resident seller, regularly in the course of his business. The aggregate purchase made
during the previous year 2021-22 on various dates is ` 80 lakhs which are as under:
10-06-2021 ` 25,00,000
20-08-2021 ` 27,00,000
12-10-2021 ` 28,00,000
He credited Mr. Agarwal's account in the books of accounts on the same date and made
the payment on the 28-02-2022 ` 80 lakh. Mr. Agarwal's turnover for the financial year
2020-21 is ` 20 crores. (6 Marks)
(b) Compute the gross total income of Mr. Prakhar for A.Y. 2022-23 and the losses to be
carried forward, from the information given below:
(i) Income from House Property (computed) ` 3,60,000
(ii) Short term capital loss on shares of a company ` (-) 18,700
(iii) Long term capital gain on sale of agricultural land ` 6,000
(iv) Income from rubber business (plants grown by Mr. Prakhar) ` 80,000
(v) Loss from garment business b/f discontinued in F.Y. 2019-20 ` (-) 70,000
(vi) Loss from betting ` (-) 5,500
(vii) Income from lotteries (net) ` 5,460
(4 Marks)
(c) Mr. A employed with B Pvt. Ltd. residing in Chennai, filed his return of Income on 30 thJuly.
He has no other income other than salary. He however has failed to link his Aadhar with
PAN as on return filing date.
(i) What is the last date for linking Aadhar with PAN?
(ii) What is the consequence for him if he has linked the Aadhar with PAN on 31 st August
2022?

(iii) Are there any exceptions provided under section 139AA from quoting of Aadhar
number? (4 Marks)
Answer
(a) (i) Tax @10% has to be deducted by S and Co. Ltd. under section 194J on directors
sitting fees of ` 25,000. The threshold limit of ` 30,000 is not applicable in respect of
sum paid to a director.
The amount of tax to be deducted at source = ` 25,000 x 10% = ` 2,500
(ii) There is no liability to deduct tax at source under section 194LA, since the payment
to Mr. Mohan, a resident, by State of Haryana on compulsory acquisition of his urban
land does not exceed ` 2,50,000.
(iii) Since Mr. Purushotham’s turnover for F.Y.2020-21 exceeds ` 10 crores, and value
of goods purchased from Mr. Agarwal, a resident seller, exceeds ` 50 lakhs in the
P.Y.2021-22, he is liable to deduct [email protected]% on ` 30 lakhs (being the sum exceeding
` 50 lakhs), at the time of credit or payment, whichever is earlier.
On 10.6.21= Nil (No tax is to be deducted u/s 194Q on the purchases made on
10.6.2021 since the purchases made till that date has not exceeded the threshold of
` 50 lakhs and TDS provisions u/s 194Q was effective from 1.7.2021)
On 20.8.2021 = 0.1% of ` 2 lakhs (amount exceeding ` 50 lakhs) = ` 200
On 12.10.2021 = 0.1% of ` 28 lakhs = ` 2,800.
(b) Computation of gross total income of Mr. Prakhar for the A.Y.2022-23
Particulars ` `
Income from house property (computed) 3,60,000
Profits and gains from business and profession
Income from rubber business [35% of income from 28,000
manufacture of rubber is business income [80,000 x 35%]
and the balance 65% would be agricultural income
Less: Brought forward loss of ` 70,000 from garment 28,000 Nil
business set-off to the extent of ` 28,000, set-off is
permissible even if the business is discontinued
Capital Gains
Long-term capital gain on sale of agricultural land
(Exempt, assuming that the same is rural agricultural land)
-
Income from Other Sources
Income from lotteries (` 5,460 x 100/70) 7,800

[Note – Tax @30% has to be deducted on winnings from

lotteries u/s 194B only if the amount of payment exceeds
` 10,000. However, in the question, winnings from lotteries
is only ` 5,460 and the word “net” is given in the bracket.
Since, the word “net” is written in the bracket in question,
main solution is given based on the view that tax has been
deducted on income from lotteries @30% and accordingly,
the lottery income is grossed up. However, since no tax is
deductible u/s 194B where lottery income does not exceed
` 10,000, the question can be answered without grossing
up the lottery income of ` 5,460. In such a case, gross total
income would be ` 3,65,460]
Losses to be carried forward to A.Y.2023-24 `
Loss from garment business pertaining to P.Y. 2019-20 42,000
(` 70,000 – ` 28,000)
Short term capital loss on shares of a company of 18,700
A.Y. 2022-23
Loss of ` 5,500 from betting can neither be set-off nor be -
carried forward.
Note – In the question, long term capital gain on sale of agricultural land is given as
` 6,000. However, it is not mentioned as to whether the same is rural agricultural land or
urban agricultural land. The main solution given above is based on the assumption that it
is rural agricultural land. An alternate solution has been given below based on the
assumption that it is urban agricultural land -
ALTERNATE SOLUTION
Computation of gross total income of Mr. Prakhar for the A.Y.2022-23
Particulars ` `
Income from house property (computed) 3,60,000
Profits and gains from business and profession
Income from rubber business [35% of income from 28,000
manufacture of rubber is business income [80,000 x 35%] and
the balance 65% would be agricultural income
Less: Brought forward loss of ` 70,000 from garment 28,000 Nil
business set-off to the extent of ` 28,000, set-off is
permissible even if the business is discontinued

Capital Gains
Long-term capital gain on sale of agricultural land, assuming 6,000
that the same is urban agricultural land.
Less: Set-off of Short-term capital loss of ` 18,700 against 6,000
long-term capital gains to the extent of ` 6,000 by virtue of
section 74(1) Nil
Income from Other Sources
Income from lotteries (` 5,460 x 100/70) 7,800
[Note – Tax @30% has to be deducted on winnings from
lotteries u/s 194B only if the amount of payment exceeds
` 10,000. However, in the question, winnings from lotteries is
only ` 5,460 and the word “net” is given in the bracket. Since,
the word “net” is written in the bracket in question, main
solution is given based on the view that tax has been
deducted on income from lotteries @30% and accordingly,
the lottery income is grossed up. However, since no tax is
deductible u/s 194B where lottery income does not exceed
` 10,000, the question can be answered without grossing up
the lottery income of ` 5,460. In such a case, gross total
income would be ` 3,65,460]
Losses to be carried forward to A.Y. 2023-24 `
Loss from garment business pertaining to P.Y. 2019-20 42,000
(` 70,000 – ` 28,000)
Short term capital loss on shares of a company of A.Y. 12,700
2022-23 (` 18,700 – ` 6,000)
Loss of ` 5,500 from betting can neither be set-off nor be -
carried forward.
(c) Every person who has been allotted PAN as on 1st July, 2017, and who is eligible to obtain
Aadhar Number, has to intimate his Aadhar Number to prescribed authority on or before
31st March, 2022.
Since, Mr. A fails to link his Aadhar number with PAN on or before 31.3.2022,
consequently, at the time of linking his Aadhaar number with PAN on 31.8.2022, he would
be liable to pay fee of ` 1,000 as per section 234H.
Yes, the following are the exceptions -
An individual who does not possess the Aadhar number or Enrolment ID and is:
(i) residing in Assam, Jammu & Kashmir and Meghalaya;

(ii) a non-resident as per Income-tax Act, 1961;

(iii) of the age of 80 years or more at any time during the previous year;
(iv) not a citizen of India
Question 4
(a) Examine whether the following are chargeable to tax and the amount liable to tax:
(i) Interest on enhanced compensation ` 3,00,000 received on 31.03.2022 from
Government of Tamil Nadu towards urban land acquired by it. 40% of enhanced
compensation interest pertains to previous year 2020-21.
(ii) Narayanan transferred 1000 shares of BS Ltd to AB Pvt. Ltd on 01-06-2021 for a
consideration of ` 2,00,000 when the fair market value of the same as on transaction
date was ` 3,00,000. The indexed cost of acquisition of shares for Narayanan was
` 2,75,000. The transfer was effected off market on which securities transaction tax
was not paid. BS Ltd is a closely held unlisted company.
(iii) Mr. A received ` 5,00,000 on 1 st March 2022 from Sree Pushpaka Charitable Trust
for meeting his medical expenses. The trust is registered under section 12AB of
Income-tax Act. (6 Marks)
(b) Ms. Priya, aged 61 years, has total income of ` 7,50,000, including income from
profession, for A.Y. 2022-23, and has paid advance tax of ` 10,000 on 13.12.2021. She
has filed her return of income on 15.06.2022.
Calculate the self-assessment tax payable and the interest thereon u/s 234A, 234B and
234C, if any, by Ms. Priya. (4 Marks)
(c) Mr. X a resident, aged 56 years, till recently was a successful businessman filing his return
of incomes regularly and promptly ever since he obtained PAN card. During the COVID -
Pandemic period his business suffered severely and he incurred huge losses. He was not
able to continue his business and finally on 1 st January, 2022 he decided to wind-up his
business which he also promptly intimated to the jurisdictional Assessing Officer about the
closure of his business.
The Assessing Officer sent him a notice to tax income of A.Y. 2022-23 during the
A.Y. 2021-22 itself. Does the Assessing Officer have the power to do so? Are there any
exceptions to the general rule “Income of the previous year is assessed in the assessment
year following the previous year”? (4 Marks)
OR
From the following transactions compute the total income of Mr. Raman and his wife Savita
for the Assessment year 2022-23.
(i) Mr. Raman had a fixed deposit of ` 5,00,000 in the bank. He instructed the bank to
credit the interest on deposit @6% from 01-04-2021 to 31-03-2022 to the savings
account of his brother’s son for his education.

(ii) Savita is a B.com graduate and working in the ABC Private Limited as an accountant
with a monthly salary of ` 25,000. Raman holds 30% equity shares of the ABC Private
Limited.
(iii) Raman started proprietary business on 01-04-2000 with a capital of ` 10,00,000. He
incurred a loss of ` 2,00,000 during the previous year 2020-21. To overcome the
financial position, Savita gifted a sum of ` 4,00,000 to him on 01-04-2021 which was
immediately invested in the business by Mr. Raman. He earned a profit of ` 3,00,000
during the previous year 2021-22
(iv) Sajan, younger son of Raman, aged 17 years won in a debate competition during the
annual competitions held at his school and received a cash award of ` 10,000 and
he also earned interest of ` 7,000 on balance maintained in his savings bank account.
(4 Marks)
Answer
(a) (i) Interest on enhanced compensation received on 31.03.22 from Government of Tamil
Nadu (including 40% of interest on enhanced compensation relating to P.Y. 2020 -21)
would be deemed to be the income of P.Y. 2021-22, being the year in which it is
received irrespective of the method of accounting followed by the assessee.
Interest of ` 3,00,000 on enhanced compensation is chargeable to tax during the P.Y.
2021-22 after providing deduction of 50% under section 57. Therefore, ` 1,50,000 is
chargeable to tax under the head “Income from other sources”.
(ii) In the hands of Mr. Narayanan
Since the consideration of ` 2,00,000 is less than ` 3,00,000, being the fair market
value of unquoted shares of BS Ltd., the fair market value of shares i.e., ` 3,00,000
would be deemed to be the full value of consideration.
Accordingly, ` 25,000 [` 3,00,000 – ` 2,75,000, being indexed cost of acquisition]
would be liable to tax as long term capital gains in the hands of Mr. Narayanan.
In the hands of AB Pvt. Ltd.
Shares received by AB Pvt. Ltd. from Mr. Narayanan for inadequate consideration is
chargeable to tax, since the difference exceeds ` 50,000. Accordingly, ` 1,00,000,
being the difference between aggregate Fair Market Value of the shares i.e.,
` 3,00,000 and consideration i.e., ` 2,00,000 would be chargeable to tax under the
head “Income from other sources”.
(iii) The sum of ` 5,00,000 received from Sree Pushpaka Charitable Trust, without
consideration, for meeting medical expenses would not be chargeable to tax in the
hands of Mr. A, since the same is received from a trust registered under section 12AB.

(b)
Self assessment tax payable [It is assumed Ms. Priya is not opting for section
115BAC] [See Note and Alternative thereto]
Tax on ` 7,50,000
Upto ` 3,00,000 Nil
` 3,00,001 – ` 5,00,000 @5% 10,000
` 5,00,001 – ` 7,50,000 @20% 50,000
60,000
Add: Health and education cess @4% 2,400
62,400
Less: Advance tax 10,000
Tax payable 52,400
Add: Interest under section 234A [Interest under section 234A would not be -
attracted, since Ms. Priya has furnished her return of income on 15.06.2022
which is before the due date of filing return of income]
Add: Interest under section 234B would be levied on ` 52,400 at 1% for 3 1,572
months i.e., From April to June. The interest under section 234B amount to
` 1,572
Add: Interest under section 234C 2,747
Date of Specified Amount due and Period Interest
Instalment % of unpaid (rounded off @ 1%
estimated to nearest ` 100,
tax ignoring fraction)
15th June 2021 15% 9,300 [15% of 3 months 279
` 62,400]
15th September 45% 28,000 [45% of 3 months 840
2021 ` 62,400]
15th December 75% 36,800 [(75% of 3 months 1104
2021 ` 62,400) –
` 10,000]
15th March 2022 100% 52,400 1 month 524
Total interest under section 234C 2,747
Self assessment tax payable and interest thereon 56,719

Self assessment tax payable and interest thereon (rounded off) 56,720

Note - The question does not mention that Ms. Priya has opted for section 115BAC, in
which case the total income given therein would be as per the regular provisions of the
Act. The main solution has been worked out accordingly as per the regular provisions of
the Act.
Since there is no mention of Chapter VI-A or other deductions claimed by her, it is possible
to assume that she has not claimed any such deduction, in which case, it would be
beneficial for her to opt for section 115BAC. Based on the assumption that she has opted
for section 115BAC and the total income given in the question reflects the computation
accordingly, the alternative answer would be as follows:
Self assessment tax payable [It is assumed Ms. Priya has opted for section 115BAC]
Tax on ` 7,50,000 `
Upto ` 2,50,000 [not eligible for higher basic exemption limit] Nil
` 2,50,001 – ` 5,00,000 @5% 12,500
` 5,00,001 – ` 7,50,000 @10% 25,000
37,500
Add: Health and education cess @4% 1,500
39,000
Less: Advance tax 10,000
Tax payable 29,000
Add: Interest under section 234A [Interest under section 234A would not be -
attracted, since Ms. Priya has furnished her return of income on 15.06.2022
which is before the due date of filing return of income]
Add: Interest under section 234B would be levied on ` 29,000 at 1% for 3 870
months i.e., from April to June. The interest under section 234B amount to
` 870.
Add: Interest under section 234C 1,565
Date of Specified Amount due and Period Interest
Instalment % of unpaid (rounded off @ 1%
estimated to nearest
tax ` 100, ignoring
fraction)
15th June 2021 15% 5,800 [15% of 3 months 174
` 39,000]
15th September 45% 17,500 [45% of 3 months 525
2021 ` 39,000]
15th December 75% 19,200[(75% of 3 months 576
2021 ` 39,000) – `10,000]

15th March 2022 100% 29,000 1 month 290 ----------

Total interest under section 234C 1,565
Self assessment tax payable and interest thereon 31,435
Self assessment tax payable and interest thereon(rounded off) 31,440
(c) [First Alternative]
Yes, he has the power to do so.
Since the business of Mr. X is discontinued on 1st January, 2022, the income of the
period from 1.4.2021 to 1.1.2022 may, at the discretion of the Assessing Officer, be
charged to tax in A.Y.2021-22 itself.
Following are the other exceptions to the general rule “Income of the previous year is
assessed in the assessment year following the previous year” i.e., the income of the
previous year is assessed in the previous year itself.
(i) Shipping business of non-resident
(ii) Persons leaving India with no present intention of returning
(iii) AOP/BOI/Artificial Juridical Person formed for a particular event or purpose and
likely to be dissolved
(iv) Persons likely to transfer property to avoid tax.
(c) [Second Alternative]
Computation of Total Income of Mr. Raman and Mrs. Savita for A.Y. 2022-23
Particulars Mr. Raman Mrs. Savita
Amount (`)
(i) Interest on fixed deposits [Income would be 30,000
included in the hands of Raman, since he has
transferred income to his brother’s son without
transfer of the asset, being fixed deposit]
[` 5,00,000 x 6%]
(ii) Salary income [` 3,00,000 (` 25,000 x 12) less 2,50,000
standard deduction of ` 50,000]
[Mrs. Savita’s salary would not be included in the
income of Raman, who has substantial interest in
the company, since she possesses the relevant
professional qualifications for working as an
accountant]
(iii) Savita gifted ` 4,00,000 to Mr. Raman, which 2,00,000 1,00,000
Mr. Raman has invested in the business. In such
case, proportionate income (i.e., 1/3 x
` 3,00,000) arising from such investment is to be

included in the total income of Savita.

Mr. Raman’s contribution in capital as on
1.4.2021 = ` 8,00,000 [` 10,00,000 – ` 2,00,000]
Mrs. Savita’s contribution on 1.4.2021 =
` 4,00,000
` 3,00,000, being the profit for P.Y.2021-22 to be
apportioned on the basis of capital employed on
the first day of the previous year i.e., as on
1.4.2021 (8:4 or 2:1)
Total income [before considering minor income 2,30,000 3,50,000
from interest on savings account]
(iv) Cash award won in a debate by Sajan, minor son,
would not be included in the hands of either -
parent, since such income arises from his own -
skills/talent.
However, interest of ` 7,000 on savings bank
account (after providing for deduction of ` 1,500)
is to be included in the hands of Mrs. Savita, since
her income is higher than that of her husband
[` 7,000 - `1,500] - 5,500
Gross Total Income 2,30,000 3,55,500
Less: Deduction under section 80TTA (Interest on
savings bank account) - 5,500
Total Income 2,30,000 3,50,000

SECTION B: INDIRECT TAXES

1. Section B comprises of questions from 5-8. In Section B, answer question no. 5 which is
compulsory and any two questions from question nos 6-8.
2. Working notes should form part of the answer.
3. All questions in Section B should be answered on the basis of position of GST law as
amended by the Finance Act, 2021 as well as significant notifications/ circulars issued upto
30th April, 2022.
Question 5
Ajay Limited, a registered dealer in Patna (Bihar), is engaged in various types of supplies. The
company provided the following details for the month of January 2022:
Sl. Particulars Amount in
No. `
(i) Outward supply of goods made during the month to various non- As given in
related persons: particulars
Particulars Market Transaction column
value Value (`)
a. in the State of Bihar (Intra- 3,00,000 4,00,000
State)
b. to other States (Inter-State) 2,00,000 1,00,000
(ii) Services provided to the State Government of Karnataka for 5,00,000
conducting a computer training programme for its employees. Total
expenditure incurred for the said programme was ` 90,000, of which
` 63,000 was borne by the State Govt. (Inter-State transaction)
(iii) Stock transfer without consideration to its branch at Gaya (Bihar). Nil
Branch has separate GSTN for convenience of accounting and
billing.
Value under section 15 - ` 20,000 (Intra -State)
(iv) Intra - State inward supply of various services for use in the course 6,50,000
or furtherance of business (30 invoices)
Additional Information:
(a) All the amounts given above are exclusive of taxes.
(b) During the course of arranging and filing documents, the accountant of Ajay Limited
observed that an invoice for ` 30,000 (excluding tax) dated 02.12.2021 was omitted to be
recorded in the books of accounts and no payment was made against the same till the end
of January 2022. This invoice was issued by Mr. Mukesh of Patna, from whom Ajay Limited
had taken cars on rental basis. Invoice included cost of fuel also. (Intra -State transaction).

(c) Rate of GST applicable on various supplies are as follows:

Nature of supply CGST SGST IGST
Car rental service 2.5% 2.5% 5%
All other inward and outward supplies 9% 9% 18%
(d) No opening balance of input tax credit exists in the beginning of the month.
(e) Out of the 30 invoices of inward supply received, 6 invoices with taxable value amounting
to ` 1,50,000 were e-invoices in which Invoice Reference Number (IRN) was not
mentioned. However, all the invoices were duly reflected in GSTR 2B for the month of
January 2022, since the suppliers had filed their GSTR-1.
(f) Subject to the information given above, conditions necessary for claiming ITC were
complied with.
You are required to calculate the amount of net GST liability payable in cash by Ajay Limited for
the month of January 2022. Brief notes for treatment given for each item should form part of
your answer. (8 Marks)
Answer
Computation of net GST payable in cash by Ajay Ltd. for the month of January 2022
Particulars CGST (`) SGST (`) IGST (`)
Outward intra-State supply of goods made in 36,000 36,000
the State of Bihar [4,00,000 × [4,00,000 ×
[Value of supply is the transaction value of 9%] 9%]
the goods.]
Outward supply of goods made to other 18,000
States [1,00,000 ×
[Value of supply is the transaction value of 18%]
the goods.]
Inter-State services provided to State 90,000
Government of Karnataka for conducting a [5,00,000 ×
computer training programme 18%]
[Not exempt since the State Government has
borne less than 75% of total expenditure of
the training programme.]
Intra-State stock transfer to Gaya Branch 1,800 1,800
with separate registration [20,000 × [20,000 ×
[Supply of goods between distinct persons in 9%] 9%]
course or furtherance of business qualifies as
supply even if made without consideration.]

Total output tax 37,800 37800 1,08,000

Less: Input Tax Credit [Refer Working Note (37,800) (7,200)
below] (CGST) (CGST)
[CGST credit should be utilized for payment (37,800) (7,200)
of CGST and IGST in that order. Similarly,
(SGST) (SGST)
SGST credit should be utilized for payment of
SGST and IGST in that order. ITC of CGST
cannot be utilized for payment of SGST and
vice versa.]
Net GST payable in cash Nil Nil 93,600
Working Note:
Computation of ITC available
Particulars CGST (`) SGST (`) IGST (`)
Intra-State inward supply of services 45,000 45,000 --
[` 6,50,000 – `1,50,000] [5,00,000 × [5,00,000 ×
[ITC cannot be claimed on the e-invoices without 9%] 9%]
IRN since an e-invoice without IRN is not treated
as valid document for claiming ITC.]
Cars taken on rental basis from Mr. Mukesh -- -- --
[Tax on renting of motor car services wherein
cost of fuel is included in consideration provided
by a non-body corporate to a body corporate and
invoice is issued charging CGST/SGST @ 2.5%
is payable under reverse charge.
Time of supply of such services is 1 st February
being earlier of date of payment, or date
immediately following 60 days since issue of
invoice by the supplier. Since the time of supply
of renting of motor car services in the given case
does not fall in January, tax liability on the same
does not arise in said month.
Further, ITC on renting of motor car services
received is blocked since the recipient - Ajay Ltd.
is not in the same line of business 1.]
Total ITC available 45,000 45,000 --
1
It has been most logically assumed that Ajay Ltd. is not engaged renting of cars business.

Question 6
(a) Charm Limited, registered under GST in the State of Jharkhand, manufactures cosmetic
products and appointed Mr. Handsome of Mumbai, who is registered under GST in the
State of Maharashtra, as their Del-credere agent (DCA) to sell their products. Being a DCA,
he agrees to raise invoices in his own name and also guarantees for the realization of
payments from customers to Charm Limited.
In order to realize the payments from customers on time, he extends short term transaction
based loans to them and charges interest for the same.
Mr. Handsome provides you the following details of transactions carried out during the
month of March 2022:
Sl. Particulars Amount
No. in (` )
Outward supply:
i. Goods sold by Mr. Handsome in his DCA capacity (intra -State 2,80,000
transaction)
ii. Interest earned from the above customers for short term credit 20,000
facility provided for timely payment of dues. (intra-State
transaction)
iii. Commission bill raised on Charm Limited (inter-State transaction) 30,000
in respect of DCA services provided.
Inward supply:
iv Inter-State supply of goods received from Charm Limited. Being a Nil
DCA, no consideration was paid.
Value under section 15 - ` 2,00,000
v. Received training in marketing and distribution from Charm Limited Nil
as per DCA agreement, free of cost.
Company charges ` 75,000 for such training when it provides the
same to others.
Applicable rate of tax on both inward and outward supplies is 9% each for CGST and SGST
and 18% for IGST. Amounts given above are exclusive of taxes wherever applicable.
Subject to the information given above, necessary conditions are complied with for
availment of input tax credit.
You are required to calculate the gross GST liability and eligible input tax credit for the
month of March 2022 of Mr. Handsome. Brief notes should form part of your answer for
treatment of items in Sl. No. (i) to (v). (6 Marks)

(b) Answer the following, after reading the below given two paragraphs:
(i) Briefly discuss the relevant provision
(ii) decide the correct conclusion and
(iii) determine the validity of the given advice (Correct/Incorrect)
(I) Raju is engaged in the manufacture of 'Fly ash Bricks' in the State of Kerala. He
started his activity in the month of April 2022 and deals only in intra-State. His tax
consultant advised him to register under composition levy under GST as Raju's
turnover is expected to be below ` 1 crore for the said financial year.
(II) Dharun provides service as a business facilitator to Zio Bank Limited by facilitating in
opening of bank accounts to villagers in its rural branches in Punjab and earned a
commission of ` 22 lakh in the month of April, 2022. So far he is not registered under
GST. Dharun's tax consultant advised him that he is liable for registration under GST
as his gross receipts exceeded ` 20 lakh. Dharun has no other receipt / business
activity other than the above. (4 Marks)
Answer
(a) Computation of gross GST liability of Mr. Handsome for the month of March 2022
Particulars CGST SGST IGST
(`) (`) (`)
Goods sold by Mr. Handsome in his 2,80,000 27,000 27,000
DCA capacity [3,00,000 [3,00,000
Add: Interest earned for short term 20,000 × 9%] × 9%]
credit facility provided to above
customers
[Interest included in the value of supply
of the goods sold since where DCA is
an agent under Schedule - I of the
CGST Act, short term credit facility
provided by DCA to the buyer is
subsumed in the supply of the goods by
the DCA to the buyer.]
Commission charged for DCA services 5,400
[Being taxable supply of services.] [30,000
× 18%]
Gross GST liability 27,000 27,000 5,400
Note: Since the invoice for goods sold is issued by the DCA – Mr. Handsome in his
own name, he would fall under the ambit of an agent under Schedule – I of the CGST
Act.

Computation of eligible ITC for the month of March 2022

Particulars CGST SGST IGST (`)
(`) (`)
Inward supply of goods from Charm Limited free 36,000
of cost [2,00,000
[Supply of goods by principal – Charm Limited to × 18%]
the agent – Mr. Handsome qualifies as supply
even though it is made without consideration.]
Training in marketing and distribution received -- -- --
from Charm Limited free of cost
[Since no consideration is charged for the
services provided, said services do not qualify as
supply. As no GST is paid on the same, ITC is not
available]
Total ITC available Nil Nil 36,000
(b) (I) A registered person whose aggregate turnover in the preceding financial year did not
exceed ` 1.5 crore in a State/UT may opt for composition scheme subject to fulfilment
of specified conditions.
One of these conditions is that he must not be engaged in the manufacture of notified
goods including fly ash bricks.
Therefore, in the given case, since Raju is engaged in manufacture of fly ash bricks,
he cannot opt for composition levy even though his aggregate turnover in the
preceding financial year is nil.
Thus, the advice given by his tax consultant is not correct.
(II) Services by a business facilitator to a banking company with respect to accounts in
its rural area branch is exempt from GST.
Since in the given case, Dharun is engaged exclusively in providing the exempt
services, it is not liable to obtain registration even though his aggregate turnover
exceeds ` 20 lakh.
Thus, the advice given by his tax consultant is not correct.
Question 7
(a) Nesamani started his business activities in the month of February 2022 in the State of
Orissa. He provided the following details:

Particulars Amount in `
(i) Outward supply of petrol (Intra State) 4,00,000
(ii) Transfer of exempt goods to his branch in Rajasthan (Inter- 2,00,000
State)
(iii) Outward supply of taxable goods by his branch in Uttar 5,00,000
Pradesh (Intra State)
(iv) Outward supply of services on which tax is payable under 6,00,000
RCM by the recipient of services (Intra-State)
(v) Inward supply of services on which tax is payable under RCM 2,00,000
(Intra- State)
From the information given above, compute the aggregate turnover of Nesamani and also
decide whether he is required to get registration under GST. Assume that the amounts
given above are exclusive of taxes. (5 Marks)
(b) (i) Pranesh has deposited a sum of ` 5,000 under the head of ‘Fee’ column of Cess and
`4,000 was lying unutilized under the head of ‘Penalty’ column of IGST. Both the
deposits were made wrongly instead of depositing under the head of Fee column
under SGST.
In the light of the provisions of section 49(10) & 49(11) of the CGST Act, 2017, briefly
explain the relevant provisions as how can Pranesh rectify these errors? (3 Marks)
(ii) M/s Sakura Enterprises made an inter-State supply of taxable goods valued at
` 47,500 and exempt goods valued at ` 2,000. Rate of IGST for taxable supply was
6%. Determine, with brief reasons, whether e-way bill generation is mandatory for the
above supply made by M/s Sakura Enterprises. (2 Marks)
Answer
(a)
Particulars Amount (`)
Computation of aggregate turnover of Nesamani
Outward supply of petrol 4,00,000
[Supply of petrol being a non-taxable supply is an exempt supply.
Value of exempt supply is includible in aggregate turnover.]
Inter-State stock transfer of exempt goods 2,00,000
[Supply of taxable/exempt goods between distinct persons is
includible.]
Outward supply of taxable goods from Uttar Pradesh branch 5,00,000
[Value of outward supplies under same PAN are includible.]

Outward supply of services taxable under reverse charge 6,00,000

[Includible in aggregate turnover.]
Inward supply of services taxable under reverse charge --
[Excludible from the aggregate turnover.]
Aggregate turnover 17,00,000
For a supplier engaged in supply of goods and services from the States of Orissa and Uttar
Pradesh, the threshold limit of aggregate turnover to obtain registration is ` 20 lakh.
However, a person required to pay tax under reverse charge has to obtain registration
compulsorily irrespective of the quantum of turnover.
Since in the given case, Nesamani is required to pay tax under reverse charge, it is liable
to obtain registration compulsorily irrespective of his quantum of turnover.
(b) (i) A registered person is allowed to make intra-head or inter-head transfer of amount,
as available in electronic cash ledger, using specified form.
It can transfer any amount of tax, interest, penalty, fee or others, under one (major or
minor) head to another (major or minor) head, as available in the electronic cash
ledger.
Therefore, in the given case, amount of ` 5,000 available under minor head ‘fee’ of
major head ‘cess’ and ` 4,000 available under minor head ‘penalty’ of major head
‘IGST’ can be transferred to minor head ‘fee’ of major head ‘SGST’ using specified
form.
(ii) In the given case, consignment value of goods (including GST and excluding value
of exempt supply) is ` 50,350 (47,500 × 106%).
Since there is a movement of goods of consignment value exceeding ` 50,000, M/s
Sakura Enterprises is mandatorily required to issue e-way bill.
Question 8
(a) Rule 86B restricts the use of Input Tax Credit (ITC) available in the Electronic Credit Ledger
for discharging output tax liability. List down the exceptions to the rule 86B.
(5 Marks)
(b) List any three situations that warrant issue of credit note. Briefly explain the time line to
declare such credit note in the GST return.
OR
List the details of outward supplies which can be furnished using Invoice Furnishing Facility
(IFF). Also briefly list the cases where a registered person is debarred from furnish ing
details of outward supplies in GSTR-1/IFF. (5 Marks)

Answer
(a) Rule 86B of the CGST Rules, 2017 restricts the use of ITC available in the Electronic Credit
Ledger for discharging output tax liability by a registered person. Exceptions to rule 86B
are as follows:
(1) Where the said person/proprietor/karta/managing director/any of its two partners,
whole-time directors, members of Managing Committee of Associations or Board of
Trustees, as the case may be, have paid more than ` 1 lakh as income tax in each
of the last 2 financial years.
(2) Where the registered person has received a refund of more than ` 1 lakh in the
preceding FY on account of unutilised ITC in case of
(i) zero rated supplies made without payment of tax or
(ii) inverted duty structure.
(3) Where the registered person has discharged his liability towards output tax through
the electronic cash ledger for an amount which is in excess of 1% of the total output
tax liability, applied cumulatively, upto the said month in the current FY.
(4) Where the registered person is Government Department, Public Sector Undertaking,
Local authority or Statutory body. Said restriction may be removed by Commissioner/
authorised officer after required verifications and safeguards.
(b) Situations that warrant the issue of credit note are as follows:
• The supplier has erroneously declared a value which is more than the actual value of
the goods or services provided.
• The supplier has erroneously declared a higher tax rate than what is applicable for
the kind of the goods or services or both supplied.
• The quantity received by the recipient is less than what has been declared in the tax
invoice.
• The quality of the goods or services or both supplied is not to the satisfaction of the
recipient thereby necessitating a partial or total reimbursement on the invoice value.
The details of credit note are declared in the GST return for the month during which such
credit note has been issued but not later than:
(i) September following the end of the financial year in which such supply was made,
or
(ii) the date of furnishing of the relevant annual return,

whichever is earlier.
Alternative answer (b)
Details of outward supplies which can be furnished using IFF are as follows:
(a) invoice wise details of inter-State and intra-State supplies made to the registered
persons;
(b) debit and credit notes, if any, issued during the month for such invoices issued
previously.
Cases where a registered person is debarred from furnishing details of outward supplies
in GSTR-1/using IFF:
(i) A registered person is not allowed to furnish Form GSTR-1, if he has not furnished
the return in Form GSTR-3B for the preceding 2 months 2/ for the preceding 1 month 3.
(ii) A registered person, opting for QRMP (Quarterly Return Monthly Payment) scheme
is not allowed to furnish Form GSTR-1/using IFF, if he has not furnished the return in
Form GSTR-3B for preceding tax period.
2 Position of law till 31.12.2021

3 Position of law w.e.f. 01.01.2022

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PAPER – 4 : TAXATION

SECTION A : INCOME TAX LAW

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Purchase of furniture at 1,35,000

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Loss from self-occupied property (30,000)

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general rate for plant and machinery. The main

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Income earned from gift to daughter in law

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III Income from Other Sources 57,500

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1 It is assumed that he has fully expended the amount

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Research and training allowance [` 3,000 x 12] 36,000

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[Note – Tax @30% has to be deducted on winnings from

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(ii) a non-resident as per Income-tax Act, 1961;

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Self assessment tax payable and interest thereon 56,719

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© The Institute of Chartered Accountants of India

15th March 2022 100% 29,000 1 month 290 ----------

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included in the total income of Savita.

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SECTION B: INDIRECT TAXES

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(c) Rate of GST applicable on various supplies are as follows:

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Total output tax 37,800 37800 1,08,000

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© The Institute of Chartered Accountants of India

© The Institute of Chartered Accountants of India

Computation of eligible ITC for the month of March 2022

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© The Institute of Chartered Accountants of India

Outward supply of services taxable under reverse charge 6,00,000

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© The Institute of Chartered Accountants of India

2 Position of law till 31.12.2021

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