CS Professional · June 2026 · Paper 4.5
CS Professional Advanced Direct Tax Laws and Practice June 2026: 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.
| Q | Marks | Tests | Chapter |
|---|---|---|---|
| 1(a) | 15 | Company under concessional regime: computing house property and business income with disallowances and timing-based deductions | Computation of Total Income, Tax Liability and Filing of Return of Companies |
| 1(b) | 5 | Company under concessional regime: capital gains, other sources income and gross total income | Computation of Total Income, Tax Liability and Filing of Return of Companies |
| 1(c) | 5 | Company under concessional regime: total income and net tax liability | Computation of Total Income, Tax Liability and Filing of Return of Companies |
| 2(a) | 3 | Purpose of reference to a valuation officer during assessment | Assessment |
| 2(b) | 3 | Whether reference to a valuation officer is possible when the assessing officer accepts the declared value | Assessment |
| 2(c) | 3 | Valuation officer powers where the assessee does not cooperate | Assessment |
| 2(d) | 3 | Submission and time limit for the valuation report | Assessment |
| 2(e) | 3 | Assessee safeguards before the valuation report is used in assessment | Assessment |
| 3(a) | 5 | Total income of a co-operative society with deduction for specified activities | Computation of Total Income, Tax Liability and Filing of Returns of various Entities excluding Companies |
| 3(b) | 5 | Applicability of presumptive taxation for business versus profession where professional fee TDS applies | Computation of Total Income, Tax Liability and Filing of Returns of various Entities excluding Companies |
| 3(c) | 5 | Tax consequences of cash payments for purchases above the prescribed limit for buyer and seller | Computation of Total Income, Tax Liability and Filing of Returns of various Entities excluding Companies |
| 4(a) | 5 | Company dividend income, allowable expenses and inter-corporate dividend deduction | Computation of Total Income, Tax Liability and Filing of Return of Companies |
| 4(b) | 5 | Carry forward of losses where the return is filed only in response to a notice | Assessment |
| 4(c) | 5 | Tax liability of a resident with foreign income and unilateral relief where no tax treaty exists | Double Taxation Avoidance Agreement (DTAA) |
| 4A(i) | 5 | Penalty for failure to get accounts audited and reasonable cause defence | Tax Audit |
| 4A(ii) | 5 | Validity of reopening an assessment when refund processing is pending | Assessment |
| 4A(iii) | 5 | Time limits and approval for reassessment notice following a search | Assessment |
| 5 | 15 | Individual under old regime: inter-head set-off, carry forward of losses, gifts and deemed income, deductions and tax liability | Computation of Total Income, Tax Liability and Filing of Returns of various Entities excluding Companies |
| 6(a) | 5 | Consequences of transfer pricing adjustments and remedies available to the assessee | Transfer Pricing and General Anti Avoidance Rules (GAAR) |
| 6(b) | 5 | Limitation on interest deduction on borrowings from a foreign associated enterprise | Income Tax Implication on Specified Transactions |
| 6(c) | 5 | Applicability of GAAR in specified independent situations | Transfer Pricing and General Anti Avoidance Rules (GAAR) |
| 6A(i) | 5 | Factors for selecting the most appropriate transfer pricing method | Transfer Pricing and General Anti Avoidance Rules (GAAR) |
| 6A(ii) | 5 | Arm's length price using comparable uncontrolled price with adjustments for functional differences | Transfer Pricing and General Anti Avoidance Rules (GAAR) |
| 6A(iii) | 5 | Total income of a salaried individual with business loss, capital loss and virtual digital asset gains | Computation of Total Income, Tax Liability and Filing of Returns of various Entities excluding Companies |
What stood out
- Entirely application-based on the compulsory path: 100 marks of computations and problem situations; the only theory part was the alternative on transfer pricing method selection.
- Computation chapters dominated: 30 marks for companies (including a 25-mark Q1 under the concessional regime) and 30 marks for non-corporate assessees (including a 15-mark individual computation).
- Assessment carried 20 marks on the compulsory path, with Q2 split into five 3-mark parts on reference to a valuation officer.
- International taxation drew 20 marks on the compulsory path: transfer pricing and GAAR 10, interest limitation on foreign-AE borrowing 5, and foreign tax relief 5.
- Appeals was not tested, and Tax Audit appeared only in alternative 4A(i).
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, Assessment: study guides and practice questions in the CS Professional format.