Jim Crow Tex. Inc. is a company incorporated in London (England). 60% of its shares are held by Sampat Pvt. Ltd. a domestic company. Jim Crow Tex. Inc. has its presence in India also. The data relating to Jim Crow Tex. I

(a) Income Criteria: The passive income should not be more than 50% of its total income. Total Income during the previous year 2018-19 is ₹100 crores [(16 crore + 29 crore) + (37 crores + 18 crores)] Passive Income is ₹47 crores being income from investment (29 crores in India and 18 crores in England). % of passive income to total income = 47 crores / 100 crores * 100 = 47% Since passive income is 47% i.e. not more than 50% of its total income, the income condition for Active Business Outside India 'ABOI' test is satisfied . (b) Assets Criteria: Should have less than 50% of its total assets situated in India Value of Total Assets during the previous year 2018-19 is ₹500 crores [160 crores in India + 340 crores in England]. Value of total Assets in India during the previous year 2018-19 is ₹160 crores. % of assets situated in India to total assets = 160 crores / 500 crores * 100 = 32% Since the value of assets situated in India is less than 50% of its total assets i.e. 32%, the assets condition for Active Business Outside India 'ABOI' test is satisfied . (c) Employee Criteria: Less than 50% of the total number of employees should be situated in India or should be resident in India. Number of employees situated in India or resident in India is 70. Total number of employees is 100 (70+30). % of employees situated in India or are resident in India to total number of employees is 70/100 * 100 = 70% Since employees situated in India or are resident in India are more than 50% of its total employees i.e. 70%, the employee condition for Active Business Outside India 'ABOI' test is not satisfied .