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CA Final · January 2026 · Paper 4

CA Final Direct Tax Laws & International Taxation January 2026: paper analysis

Our own analysis of the official paper, as of 12 October 2026. The questions and answers belong to ICAI; read them on ICAI's website.

Chapter-wise marks

Where the marks were in this paper (out of 100; internal-choice alternatives not double counted).

What each question tested

In our words, by question number. Open the official paper for the full question.

QMarksTestsChapter
114Total income and tax of a multi-unit manufacturing company with business adjustments, depreciation and compensation receipts, and evaluating the concessional regimeProfits and Gains of Business or Profession
2(a)4Intra-group transfer of land between holding and subsidiary, later converted into stock-in-trade and soldCapital Gains
2(b)4Tax consequences of a share buyback for the company and the shareholder, before and after the change in regimeAssessment of Various Entities
2(c)6Total income of a non-resident Indian opting for special provisions on foreign exchange assets, with other Indian incomesNon Resident Taxation
3(a)(i)6Computing total income of a registered educational trust, including application of income and anonymous donationsAssessment of Trusts and Institutions, Political Parties and Other Special Entities
3(a)(ii)2Exemption for a small educational institution without separate approval, based on receipts thresholdAssessment of Trusts and Institutions, Political Parties and Other Special Entities
3(b)6Total income and tax of a resident with income from non-treaty countries, including unilateral reliefDouble Taxation Relief
4(a)(i)2TDS on purchase of immovable property where stamp duty value exceeds considerationDeduction, Collection and Recovery of Tax
4(a)(ii)4TDS on large cash withdrawals from a co-operative bank by return filers and non-filersDeduction, Collection and Recovery of Tax
4(a)(iii)2TDS on taxable maturity proceeds of a life insurance policyDeduction, Collection and Recovery of Tax
4(b)6Arm's length price for services to an associated enterprise under the cost plus method with comparability adjustmentsTransfer Pricing
5(a)(i)4Time limit for issuing a scrutiny notice where a defective return is later rectifiedAssessment Procedure
5(a)(ii)4Whether a rectification order is a specified order for the Dispute Resolution Committee, and monetary limitsDispute Resolution
5(a)(iii)4Eligibility and time limit to apply for compounding of offences under revised guidelines after an earlier rejectionMiscellaneous Provisions
5(b)(A)3Meaning of most favoured nation clauses and base erosion and profit shifting in the context of tax treatiesApplication and Interpretation of Tax Treaties
5(b)(B)3Taxing rights over independent personal services under the UN Model ConventionOverview of Model Tax Conventions
6(a)6Tax audit reporting of delayed payments to micro and small enterprises and related disallowanceTax Audit and Ethical Compliances
6(b)4Whether GAAR can be invoked for an offshore subsidiary and a treaty-based interest arrangementProvisions to Counteract Unethical Tax Practices
6(c)4Who qualifies as an applicant for an advance ruling based on transaction type and tax value thresholdsAdvance Rulings

What stood out

  • The 14-mark Question 1 again centred on a manufacturing company's business income, with depreciation on asset sales, a new unit and enhanced compensation receipts adding complexity.
  • Transfer pricing appeared in both parts: interest limitation and resale price method in the MCQs and a cost plus method computation with comparability adjustments in the written section.
  • Trust taxation was again worth 16 marks overall, covering corpus investment modes, accumulation, anonymous donations and a full trust income computation.
  • Black Money Act disclosure and penalty, virtual digital asset taxation and GAAR scenarios showed the examiner's continued interest in anti-avoidance and new-economy topics.
  • Question 5 offered a choice of two out of three procedural parts on scrutiny time limits, Dispute Resolution Committee eligibility and compounding of offences.

Practise the chapters that carried the marks

Profits and Gains of Business or Profession, Assessment of Trusts and Institutions, Political Parties and Other Special Entities, Deduction, Collection and Recovery of Tax: study guides and practice questions in the CA Final format.