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CA Final · September 2025 · Paper 4

CA Final Direct Tax Laws & International Taxation September 2025: 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 of a manufacturing company with business adjustments, foreign exchange hedging, employment-linked deduction and transfer of land to a group companyProfits and Gains of Business or Profession
2(a)(i)4Tax liability of an association of persons and a member where members follow different tax regimesAssessment of Various Entities
2(a)(ii)4Shareholder taxation on a share buyback and on receipt of assets in a company liquidationCapital Gains
2(b)6Total income and tax of a foreign institutional investor on securities gains and investment incomeNon Resident Taxation
3(a)8Total income of a charitable trust: application of income, accumulated amounts and corpus-funded expenditureAssessment of Trusts and Institutions, Political Parties and Other Special Entities
3(b)6Total income and tax of a resident salaried individual with foreign income from a non-treaty country, including unilateral reliefDouble Taxation Relief
4(a)(i)3TDS on purchase of a built-up flat by joint buyers, including amenities forming part of considerationDeduction, Collection and Recovery of Tax
4(a)(ii)3Employer's TDS on salary considering other income, house property loss and TCS declared by the employeeDeduction, Collection and Recovery of Tax
4(a)(iii)2TDS obligations on interest and cash withdrawals of a co-operative bank dealing with another bankDeduction, Collection and Recovery of Tax
4(b)6Associated enterprise test based on shareholding, and options after accepting a transfer pricing adjustmentTransfer Pricing
5(a)(i)4Limitation for a revision order by the Commissioner reckoned from date of passing versus date of serviceAppeals and Revision
5(a)(ii)4Validity of reassessment proceedings when rectification is time-barred and pendingAssessment Procedure
5(a)(iii)4Whether a tax-exempt trust can be treated as an assessee in default for failure to deduct tax on rentDeduction, Collection and Recovery of Tax
5(b)3Need for and objective of principles of interpretation when interpreting tax treatiesApplication and Interpretation of Tax Treaties
5(c)3Indicators of BEPS activity recommended under the measurement and monitoring action planFundamentals of BEPS
6(a)6Tax auditor's reporting on interest limitation for debt from a non-resident associated enterprise via a back-to-back depositTax Audit and Ethical Compliances
6(b)4Distinguishing tax planning, tax compliance and tax evasion in given fact patternsTax Planning, Tax Avoidance and Tax Evasion
6(c)4Withdrawal of an advance ruling application and time limit for pronouncing the rulingAdvance Rulings

What stood out

  • Business income again anchored the paper through a 14-mark corporate computation including MSME payment timing, hedging gains and employment-linked deductions.
  • A case built around a business trust and its unit holders carried 10 MCQ marks, testing distribution taxation, withholding and residential status; an area that is easy to skip.
  • TDS questions were worth 14 marks overall, with property purchase by joint buyers, salary TDS under the default regime and assessee-in-default for exempt trusts.
  • Penalty provisions for under-reporting and false entries appeared in the MCQs, reinforcing that penalty and procedure rules need precise recall.
  • International taxation was spread across non-resident and FII taxation, foreign tax credit, transfer pricing, treaty interpretation and BEPS Action 11 in roughly equal measure.

Practise the chapters that carried the marks

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