CA Final Direct Tax Laws Syllabus Structure

Author & Publication Details

Based on the verified study material, the details regarding the authorship and publishing authority of this book are as follows:

• Author / Publishing Body: The Institute of Chartered Accountants of India (ICAI) [1]* Subject: CA Final — Direct Tax Laws & International Taxation [1]* Copyright Holder: © The Institute of Chartered Accountants of India [1]---

Key Publication & Exam Applicability Summary

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💡 Exam Tip

For CA Final Direct Tax Laws & International Taxation, always verify that your preparation aligns strictly with the statutory cut-off dates and the applicable Assessment Year (A.Y. 2026–27 for May/Sept 2026 and Jan 2027 attempts). Pay close attention to amendments brought by the relevant Finance Act and recent landmark judicial pronouncements/CBDT circulars [1].

Overview of the 3-Part Syllabus Structure for CA Final Direct Tax Laws & International Taxation

Under the official curriculum prescribed by the Institute of Chartered Accountants of India (ICAI) for CA Final , the syllabus is systematically organized into three comprehensive modules/parts. This structure tests both domestic statutory proficiency and cross-border tax planning.

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Part-by-Part Syllabus Breakdown

📌 CA FINAL: DIRECT TAX LAWS & INTERNATIONAL TAXATION

• PART 1
• Corporate & Specific Entity
• Taxation
• (Approx. 40–45%)
• PART 2
• Tax Administration, Search,
• Assessment & Dispute Res.
• (Approx. 25–30%)
• PART 3
• International Taxation, TP
• & Special Tax Statutes
• (Approx. 30–35%)

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1. Part I: Substantive Direct Tax Laws & Specific Entity Taxation (~40%–45%)

This part focuses on advanced computation of total income, entity-specific tax regimes, special deductions, and anti-avoidance measures.

• Special Tax Regimes for Corporate & Non-Corporate Assessees:
• Concessional corporate tax regimes under Section 115BAA (22%) and Section 115BAB (15%).
• Minimum Alternate Tax (MAT) under Section 115JB (15% on Book Profits) and Alternate Minimum Tax (AMT) under Section 115JC (18.5%).
• Taxation of Special Entities:
• Charitable and Religious Trusts & Institutions: Registration and renewal regime under Section 12AB, computation of income under Sections 11 to 13, and accreted tax under Section 115TD.
• Pass-Through & Specialized Entities: Business Trusts (REITs / InvITs under Section 115UA), Alternative Investment Funds (AIF Category I & II under Section 115UB), and Securitisation Trusts under Section 115TCA.
• Partnership Firms / LLPs: Profit allocation, partner remuneration limits (Section 40(b)), and dissolution/reconstitution tax under Sections 9B and 45(4).
• Corporate Restructuring & Anti-Avoidance:
• Tax implications of Amalgamation, Demerger, and Slump Sale (Section 50B).
• General Anti-Avoidance Rules (GAAR): Chapter X-A (Sections 95 to 102) covering Impermissible Avoidance Arrangements (IAA) and lack of commercial substance.

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2. Part II: Tax Administration, Assessment, Search & Dispute Resolution (~25%–30%)

This part tests practical procedural compliance, investigative mechanisms, and appellate remedies under the Income-tax Act, 1961.

• Assessment & Reassessment Procedures:
• Summary Assessment (Section 143(1)), Regular Scrutiny (Section 143(3)), and Best Judgment Assessment (Section 144).
• Income Escaping Assessment & Reassessment Framework (Sections 147 to 151) including issuance of notice under Section 148A.
• Search, Seizure & Investigative Powers:
• Search & Seizure procedures under Section 132 and Requisition of Books under Section 132A.
• Appeals, Revision & Alternate Dispute Resolution:
• Appeals before the CIT (Appeals) / Joint CIT (Appeals) under Section 246A/250, ITAT under Sections 253/254, and High Court on substantial questions of law under Section 260A.
• Administrative Revision by Principal CIT/CIT on orders prejudicial to revenue (Section 263) and on assessee's application (Section 264).
• Dispute Resolution Panel (DRP) under Section 144C and Dispute Resolution Committee (DRC) under Section 245MA.
• Tax Deduction / Collection at Source (TDS/TCS) & Penalties:
• High-yield TDS provisions (Section 194C, 194J, 194Q, 194R, 194S) and TCS under Section 206C(1H)/206C(1G).
• Penalties for under-reporting/misreporting of income under Section 270A.

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3. Part III: International Taxation, Transfer Pricing & Special Acts (~30%–35%)

This part evaluates cross-border taxation, global transfer pricing mechanics, tax treaties, and anti-tax haven regulations.

• Transfer Pricing Regulations:
• Determination of Arm’s Length Price (ALP) under Section 92C using CUP, Resale Price, Cost Plus, Profit Split, and TNMM.
• Application of the Range Concept (applicable when ≥ 6 prices are available; 35th to 65th percentile) and the tolerance band (≤ 1% for wholesale, ≤ 3% for others).
• Specified Domestic Transactions (SDT): Under Section 92BA when aggregate transactions exceed ₹20 Crore.
• Secondary Adjustment (Section 92CE) and Limitation on Interest Deduction (Section 94B - thin capitalization rules).
• Non-Resident Taxation & Equalisation Levy:
• Scope of Total Income & Business Connection under Section 9(1)(i) including Significant Economic Presence (SEP).
• Equalisation Levy on online digital advertising (6%) and e-commerce supply/services (2%).
• Withholding tax obligations for non-resident payments under Section 195.
• Double Taxation Relief & Model Tax Conventions:
• Bilateral Relief under Double Taxation Avoidance Agreements (Section 90/90A) and Unilateral Relief (Section 91).
• Interpretation of OECD vs. UN Model Tax Conventions, Base Erosion and Profit Shifting (BEPS) Action Plans, and Multilateral Instruments (MLI).
• The Black Money Act, 2015:
• Provisions of The Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act, 2015 (Taxation @ 30% + Penalty @ 300% / 90%).

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Structured Comparison Summary

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💡 Exam Tip

• Section 90(2) Principle: Always evaluate whether the provisions of the domestic Income-tax Act, 1961 or the relevant Double Taxation Avoidance Agreement (DTAA) are more beneficial to the assessee. The assessee is entitled to apply whichever is more beneficial!
• Interlinking Tip: In comprehensive 14-mark questions, calculate tax under regular provisions alongside Section 115JB (MAT) to determine the final tax payable and compute any eligible MAT Credit under Section 115JAA.

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