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CS Professional · December 2025 · Paper 4.5

CS Professional Advanced Direct Tax Laws and Practice December 2025: paper analysis

Our own analysis of the official paper, as of 12 October 2026. The questions and answers belong to ICSI; read them on ICSI'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
1(a)15Computing book profit under Section 115JB for an Ind AS company with OCI items, revaluation and insolvency statusComputation of Total Income, Tax Liability and Filing of Return of Companies
1(b)5Computing minimum alternate tax payable by the companyComputation of Total Income, Tax Liability and Filing of Return of Companies
1(c)5Eligible MAT credit under Section 115JAA and its carry-forward periodComputation of Total Income, Tax Liability and Filing of Return of Companies
2(i)3Eligibility for presumptive taxation under Section 44AD with enhanced turnover limit and its target assesseesComputation of Total Income, Tax Liability and Filing of Returns of various Entities excluding Companies
2(ii)3Businesses excluded from the Section 44AD presumptive schemeComputation of Total Income, Tax Liability and Filing of Returns of various Entities excluding Companies
2(iii)3Whether presumptive income is final and whether further expenses are deductibleComputation of Total Income, Tax Liability and Filing of Returns of various Entities excluding Companies
2(iv)3Computing presumptive business income using cash and digital receipt ratesComputation of Total Income, Tax Liability and Filing of Returns of various Entities excluding Companies
2(v)3Consequences of opting out of Section 44AD within the lock-in periodComputation of Total Income, Tax Liability and Filing of Returns of various Entities excluding Companies
3(a)5Interest under Sections 234B and 234C for a company liable to MAT without advance taxComputation of Total Income, Tax Liability and Filing of Return of Companies
3(b)5Advance tax on capital gains arising late in the year and avoiding interestComputation of Total Income, Tax Liability and Filing of Returns of various Entities excluding Companies
3(c)5Section 80AB limit on a Section 80-IB deduction when another unit incurs a lossComputation of Total Income, Tax Liability and Filing of Return of Companies
4(a)5Book profit of a firm and allowable working partner remuneration under Section 40(b)Computation of Total Income, Tax Liability and Filing of Returns of various Entities excluding Companies
4(b)5Tax liability under the new regime with crypto income and short-term capital gains at special ratesComputation of Total Income, Tax Liability and Filing of Returns of various Entities excluding Companies
4(c)5Capital gains on slump sale of an undertaking with revalued assets and fair market value rulesIncome Tax Implication on Specified Transactions
4A(i)5Whether arm length price adjustment can extend to transactions with unrelated partiesTransfer Pricing and General Anti Avoidance Rules (GAAR)
4A(ii)5Limitation for issuing a Section 143(2) scrutiny notice after a defective return is rectifiedAssessment
4A(iii)5Denial of Section 10(23C) exemption to an educational trust that diverted incomeComputation of Total Income, Tax Liability and Filing of Returns of various Entities excluding Companies
515Total income and tax of a senior citizen with foreign income, deductions and unilateral relief under Section 91Computation of Total Income, Tax Liability and Filing of Returns of various Entities excluding Companies
6(a)5Testing associated enterprise status under Section 92A across loan, purchase, board, holding and guarantee situationsTransfer Pricing and General Anti Avoidance Rules (GAAR)
6(b)5Addition under Section 68 for a large gift from a relative and the burden to explain cash creditsIncome Tax Implication on Specified Transactions
6(c)5Role of technology in improving direct tax compliance and its benefitsAssessment
6A(i)5Situations where GAAR does not apply under Rule 10UTransfer Pricing and General Anti Avoidance Rules (GAAR)
6A(ii)5Alternate minimum tax for an LLP claiming a profit-linked deductionComputation of Total Income, Tax Liability and Filing of Returns of various Entities excluding Companies
6A(iii)5Applicability of transfer pricing to royalty from a subsidiary and sales to a partly held foreign companyTransfer Pricing and General Anti Avoidance Rules (GAAR)

What stood out

  • Computation dominates: Q1 (25 marks on book profit, MAT and MAT credit) and Q5 (15 marks on an individual with foreign income and Section 91 relief) together carry 40 marks.
  • Non-corporate entities are the most tested chapter by count, covering presumptive taxation under Section 44AD, partnership remuneration, advance tax, the new regime with special rates, LLP AMT and trust exemption.
  • Transfer pricing and GAAR form the optional block: arm length price scope, associated enterprise tests, Rule 10U exclusions and transfer pricing applicability.
  • Recent provisions are visible, including the enhanced Section 44AD turnover limit linked to cash receipts and taxation of virtual digital asset income alongside listed equity gains.
  • Very few pure theory parts appear; most questions apply provisions to numeric facts, rewarding practice in structured computations.

Practise the chapters that carried the marks

Computation of Total Income, Tax Liability and Filing of Returns of various Entities excluding Companies, Computation of Total Income, Tax Liability and Filing of Return of Companies, Transfer Pricing and General Anti Avoidance Rules (GAAR): study guides and practice questions in the CS Professional format.