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CA Final · May 2026 · Paper 4

CA Final Direct Tax Laws & International Taxation May 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
114Computing total income of a manufacturing company from net profit with business adjustments, and comparing regular rates with the concessional company regimeProfits and Gains of Business or Profession
2(a)4Long-term capital gains on sale of jewellery with indexation and exemption for investment in a residential houseCapital Gains
2(b)4Carry forward of business loss and unabsorbed depreciation of a closely held company after change in shareholdingAggregation of Income, Set Off or Carry Forward of Losses
2(c)6Presumptive taxation of a non-resident cruise ship operator and taxability of related-party lease rentalsNon Resident Taxation
3(a)(i)3Reference by the Assessing Officer for cancellation of a trust's registration due to a specified violationAssessment of Trusts and Institutions, Political Parties and Other Special Entities
3(a)(ii)3Deemed application of income received at year end and applied in the following year by a charitable trustAssessment of Trusts and Institutions, Political Parties and Other Special Entities
3(a)(iii)2Distribution obligations of a newly approved electoral trust to retain exemption on contributionsAssessment of Trusts and Institutions, Political Parties and Other Special Entities
3(b)6Total income and tax of a resident with foreign income under treaty and non-treaty countries, including foreign tax creditDouble Taxation Relief
4(a)(i)2TDS on benefits or perquisites in kind provided to a business distributorDeduction, Collection and Recovery of Tax
4(a)(ii)2TDS on interest paid by a partnership firm to its partnersDeduction, Collection and Recovery of Tax
4(a)(iii)2Grossing up of TDS where the payer bears tax on professional fees, and credit to the payeeDeduction, Collection and Recovery of Tax
4(a)(iv)2TDS on interest from a capital gains account deposit after the depositor's deathDeduction, Collection and Recovery of Tax
4(b)6Arm's length price using the range concept and resulting transfer pricing adjustmentTransfer Pricing
5(a)(i)4Validity of automatic vacation of an Appellate Tribunal stay order where delay is not attributable to the assesseeAppeals and Revision
5(a)(ii)4High Court appeal decided without framing the substantial question of law at admissionAppeals and Revision
5(a)(iii)4Eligibility for the Dispute Resolution Committee against a rectification order, and effect of a set-aside detention orderDispute Resolution
5(b)6Business profits and the mutual agreement procedure under the OECD and UN Model Tax Conventions, with key differencesOverview of Model Tax Conventions
6(a)6Ethical implications for a tax auditor who relied on management certificates without verifying withholding on non-resident paymentsTax Audit and Ethical Compliances
6(b)4Distinguishing tax planning, tax management and tax evasion in given fact patternsTax Planning, Tax Avoidance and Tax Evasion
6(c)4Rejection of an advance ruling application where the issue is pending before a High Court, and available remediesAdvance Rulings

What stood out

  • Question 1 remained a 14-mark corporate business income computation, now paired with a comparison against the concessional company tax regime.
  • TDS and TCS carried 16 marks across both parts, with heavy focus on TCS on overseas remittances, tour packages and buyer-side TDS on goods.
  • Trusts were tested in a four-MCQ case on accreted income on merger and in three short written parts on registration, deemed application and electoral trusts.
  • International taxation contributed about a quarter of the paper through non-resident special provisions, cruise ship presumptive taxation, foreign tax credit, transfer pricing ranges and model conventions.
  • Procedural law featured strongly in Question 5, with Tribunal stay orders, High Court substantial question of law and Dispute Resolution Committee eligibility.

Practise the chapters that carried the marks

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