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RESIDENTIAL STATUS (SEC-6)

1.1CONCEPT OF RESIDENTIAL STATUS:


Under Section 5 total income of an assessee is be chargeable to tax depending upon the
residential status of a person and place and time of accrual of such income and the Rules for
determining residential status of various types of persons are contained in Section 6.
The following norms one has to keep in mind while deciding the residential status of an
assessee:
1. Different taxable entities - All taxable entities are divided in the following categories for
the purpose of determining residential status:
a. An individual;
b. A Hindu undivided family;
c. A firm or an association of persons;
d. A joint stock company; and
e. Every other person.
2. Different residential status - An assessee is either: (a) resident in India, or (b) non-resident
in India.
However, a resident individual or a Hindu undivided family has to be (a) resident and
ordinarily resident, or (b) resident but not ordinarily resident. Therefore, an individual and a
Hindu undivided family can either be:
a. resident and ordinarily resident in India; or
b. resident but not ordinarily resident in India; or

c. non-resident in India
All other assessees (viz., a firm, an association of persons, a joint stock company and every
other person) can either be:
a. resident in India; or
b. non-resident in India.
The table given below highlights these pointsCategory

Individual/Hindu undivided family

Firm, association of persons,


joint
stock company and
every other person

Category 1

Resident in India

Category 2

Resident in India

Ordinarily resident
Not-ordinarily resident

Non-resident in India

Non-resident in India

3. Residential status for each previous year - Residential status of an assessee is to be


determined in respect of each previous year as it may vary from previous year to previous
year.
4. Different residential status for different assessment years - An assessee may enjoy different
residential status for different assessment years. For instance, an individual who has been

regularly assessed as resident and ordinarily resident has to be treated as non-resident in a


particular assessment year if he satisfies none of the conditions of section 6(1).
5. Resident in India and abroad - It is not necessary that a person, who is resident in India,
cannot become resident in any other country for the same assessment year. A person may
be resident in two (or more) countries at the same time. It is, therefore, not necessary that a
person who is resident in India will be non-resident in all other countries for the same
assessment year.

2.1RESIDENTIAL STATUS OF INDIVIDUAL :(SECTION 6(1)):


INDIVIDUAL
Test Condition under section 6(1)

YES

NO

Resident

Non Resident (NR)

Test condition under section 6(1)

YES

NO

Resident and Ordinarily Resident (ROR)

Resident and Not Ordinarily


Resident (RNOR)

1. Resident or Non-resident (NR)-Section 6(1):


To determine the residential status of an individual, it is to be ascertained whether he is
resident or a nonresident during the previous year.
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An individual will be a resident in India in any previous year, if he satisfies


at least one of the following TWO basic conditions

1) He is in India in the previous year for a period of 182 days or more OR


2) He is in India for a period of 60 days or more during the previous year AND 365 days
or more during 4 years immediately preceding the previous year
Exception:
The Second condition of 60 days or more is extended to 182 days or more in following two
circumstances:
(i).An Indian citizen leaves India during the previous year
for the purpose of taking up employment outside India. OR
As a member of the crew of an Indian ship OR.

(ii).An Indian citizen or a person of Indian origin comes on visit to India during the
previous year.
For this purpose, a per son is said to be of Indian origin if either he or any of his parents or
any of his grandparents was born in undivided India.
In both the above cases, an individual needs to be present in India for a minimum of 182 days
or more to become resident in India instead of 60 days.
If the individual satisfies any of the two conditions, he is a resident in India and if he does not
satisfy any of the conditions, he is a non - resident during that particular assessment year.

2 Resident and Ordinarily Resident [R& OR] SEC - 6(6):


Once an individual satisfies any of the above two basic conditions for a particular
assessment year, next step would be to determine whether he will be a resident and ordinarily
resident of India in that assessment year. S 6(6) provides that a person will be resident and
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ordinarily resident in India in any assessment year if he satisfies BOTH of the following two
conditions Viz he has been: -

1) Resident in India in at least 2 out of 10 previous years according to the above basic
conditions immediately preceding the relevant previous year. AND
2) In India for a period of 730 days or more during 7 years immediately preceding the
relevant previous year.
3. Resident and Not Ordinarily Resident [R&NOR]:
A resident individual, who does not satisfy BOTH of the above conditions given above,
will be a Resident but Not Ordinarily Resident in India.
In other words, an individual becomes resident but not ordinarily resident in India
If he
Satisfies at least one of the basic conditions but satisfies NONE of the additional conditions
OR
Satisfies ONLY ONE of the two additional conditions.

4. Non Resident:
An individual is a non - resident in India if he satisfies none of the basic conditions . It must
be noted that if a person satisfies the additional conditions but does not satisfy the basic
conditions, he will still be treated as Non - Resident. In such a case, additional conditions are
not relevant.

SUMMARY
From the above discussion it is brought out that an individual can either be:
(a) Resident and Ordinarily Resident in India;
(b) Resident but Not Ordinarily Resident in India or
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(c) Non Resident.


This can be depicted in the following diagram :
Important Points to be Borne in Mind while Determining the Residential Status of an
Individual
a. Residential status is always determined for the Previous Year because the assessee has
to determine the total income of the Previous Year only. In other words, as the tax is
on the income of a particular Previous Year, the enquiry and determination of the
residence qualification must confine to the facts obtaining in that Previous Year.
b. If a person is resident in India in a Previous Year in respect of any source of income,
he shall be deemed to be resident in India in the Previous Year relevant to the
Assessment Year in respect of each of his other sources of Income. [Section 6(5)]
c. Relevant Previous Year means, the Previous Year for which residential status is to be
determined
d. It is not necessary that the stay should be for a continuous period.
e. It is not necessary that the stay should be at one place in India.
f. Both the day of entry and the day of departure should be treated as the day of stay in
India [Petition No.7 of 1995 225 ITR 462 (AAR)]
g. Presence in territorial waters in India would also be regarded as stay in India.
h. A person is said to be of Indian Origin if he or either of his parents or any of his grand
parents was born in undivided India [Section 115C]

i. Official tours abroad in connection with employment in India shall not be regarded as
employment outside India.
j. A person may be resident of more than one country for any Previous Year.
k. Citizenship of a country and residential status of that country are two separate
concepts. A person may be an Indian national/Citizen but may not be a resident in
India and vice versa.
Points to be Considered by NRIs
Previous Year is period of 12 months from 1st April to 31st March. Number of days stay in
India is to be counted during this period.
Ensure that date stamped on the passport is legible.
Keep track of no. of days in India from year to year and check the same before making the
next trip to India. It is advisable to maintain a chart for the number of days stay in the current
and in the preceding seven (7) previous years.
In the 1st year of leaving India for employment outside India, ensure that you leave before
29th September. Otherwise total income of the financial year (including the foreign income)
will be taxable in India if it exceeds the basic exemption limit.
During the last year of stay abroad, on transfer of residence to India, ensure to come back
on or after Feb 1st (or Feb 2nd in case of a leap year). Since arrival before this date will result
in stay in India exceeding 59 days. However, a person whose stay in India in preceding four
(4) previous years does not exceed 365 days, he may return after September 30th of the
relevant year without loss of non-resident status.

3.1CHARGEABLE INCOME:
Section 5 of the Income-tax Act lays down the scope of total income of any previous year of
any person. The section reads as follows:
(1) Subject to the provisions of this Act, the total income of any previous year of a person
who is a resident includes all income from whatever source derived which(a) Is received or is deemed to be received in India in such year by or on behalf of such
person; or
(b) Accrues or arises or is deemed to accrue or arise to him in India during such year; or
(c) Accrues or arises to him outside India during such year:
Provided that, in the case of a person not ordinarily resident in India within the meaning of
sub-section (6) of Section 6, the income which accrues or arises to him outside India shall not
be so included unless it is derived from a business controlled in or a profession set up in
India.
(2) Subject to the provisions of this Act, the total income of any previous year of a person
who is a non resident includes all income from whatever source derived which

ILLUSTRATION:

Mr. C, a Japanese citizen left India after a stay of 10 years on 1-06-2010. During the financial
year 2011-12, he comes to India for 46 days. Later, he returns to India for 1 year on 10-102012.
Determine his residential status for the A.Y. 2013-14.
SOLUTION:
During the previous year 2012-13, Mr.C was in India for 173 days(i.e. 22 + 30 + 30 +31 + 28
+ 31 days). His stay in the last 4 years is:
2011-12

---

46

2010-11

---

62

(i.e. 30 + 31 + 1)

2009-10

---

365

(since he left India on 1-6-2010 after 10 years)

2008-09

---

365

(since he left India on 1-6-2010 after 10 years)

838
Mr. C is a resident since his stay in the previous year 2012-13 is 173 days and in the last 4
years is more than 365 days.
For the purpose of being ordinarily resident, it is evident from the above calculations, that
(i)
(ii)

His stay in the last 7 years is more than 730 days and
Since he was in India for 10 years prior to 1-6-2010, he was a resident in the least
2 out of the last 10 years preceding the relevant previous year.

Therefore, Mr. C is a resident and ordinarily resident for the A.Y.2013-14.

4.1RESIDENTIAL STATUS OF HUF: SEC-6(2):

Control and Management

Wholly and partly in India

Wholly Outside India

(1% to 100% in India)

(0% in India)

Resident

Non Resident

Further classification is based on status of karta.

1 Resident:
As per Section 6(2), a Hindu Undivided Family (HUF) will be Resident in India if
control and management of its affairs is wholly or partly situated in India and conversely, a
HUF will be non resident in India if control and management of its affairs is situated
wholly outside India. This position can be summarized as follows:
Control or Management

Status

Wholly or partly in India

Resident

Wholly outside India

Non resident

Control and management means de facto (actual) control or manage but not merely the right
to control or manage. Control and management is situated at a place where the head, the seat
and the directing power are situated.

2 Resident and ordinarily resident (ROR)

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A HUF can will be Resident and Ordinarily Resident if its Karta satisfies both the
conditions given in section 6(6) that is the Karta has been present in India: In at least 2 out of 10 previous years according to the basic condition mentioned
immediately preceding the relevant previous year and
For a period of 730 days or more during 7 years immediately preceding the previous year.

3 Resident and Not ordinarily resident (ROR):


If the Karta does not satisfy both of the two additional conditions, the HUF will be
treated as a resident but not ordinarily resident (RNOR) in India.

4 Non Resident:
A HUF will be non - resident in India if control and management of its affairs is
situated wholly outside India. It is not the basic conditions but the control and the
management of HUF which is relevant to whether the HUF is Resident or Non - Resident.
However, to determine ROR status the two additional conditions will be applicable with
reference to its Karta.
Summary:
Thus, like an Individual a HUF may be either:(a) Resident and ordinarily in India, or
(b) Resident but not ordinarily resident in India or
(c) Non - resident in India.

ILLUSTRATION:

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The business of a HUF is transacted from Australia and all the policy decisions are taken
there. Mr.E, the Karta of the HUF, who was born in Kolkata, visits India during the P.Y.201213 after 15 years. He comes to India on 1-4-2012 and leaves for Australia on 1-12-2012.
Determines the residential status of Mr. E and the HUF for A.Y.2013-14.

SOLUTION:
(i)

During the P.Y.2012-13, Mr. E has stayed in India for 245 days (i.e. 30 + 31 + 30
+ 31 + 31 + 30 + 31 + 30 + 1days). Therefore, he is a resident. However, since he
has come to India after 15 years, he cannot satisfy any of the condition for being
ordinarily resident.
Therefore, the residential status of Mr.E for the P.Y.2012-13 is resident but not

(ii)

ordinarily resident.
Since the business of HUF is transacted from Australia and nothing is mentioned
regarding its control and management, it is assumed that the control and
management is also wholly outside India. Therefore, the HUF is a non-resident for
the P.Y.2012-13.

5.1RESIDENTIAL STATUS OF A COMPANY- SECTION 6(3):


Types of Company

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Indian company

Foreign company

Always Resident in India

Control and Management

Wholly in India

Wholly or Partly outside In

(100% in India)

(0% to 99% in India

Resident

Non Resident

As per section 6(3), residential status of a company is based on its place of registration
and control and management. Indian companies are always treated as resident irrespective of
where their control or management is. Other companies will be resident if their control and
management is wholly in India. Even if the part of the management or control is outside
India, the foreign company would be treated as non -resident in India.

ILLUSTRATION:
A company is registered in Dubai, having its head office there. However, the majority of the
directors and managers resided in India. Sales contracts and other important business
functions were controlled by directors in India. What is the residential status of the company?

SOLUTION:
A foreign company is resident in India only if, during the previous year control and
management of its affairs is situated wholly in India. Control in not necessarily situated in the
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country in which the company is registered. Usually control and management of a company
is situated at the place where meetings of the directors are held. In the given case directors
and managers are residing in India. Hence, important decisions are taken India. So this
company is a resident.

6.1RESIDENTIAL STATUS OF OTHER NON-COMPANY


PERSONS SEC 6(2) / 6(4):
1 Resident S 6(2): Like the HUFs, residence of all non company persons viz a Firm, an
Association of Persons (AOP) or a Body of Individuals (BOI) and every other person will
depend upon t he place of control and management vide section 6(2).as summarised below :.

Control or Management

Status

Wholly or partly in India

Resident

Wholly outside India

Non resident

Thus, any such person will be Resident in India if control and management of its affairs is
wholly or partly situated in India and conversely, it will be non resident in India if control
and management of its affairs is situated wholly outside India.
Control and management means de facto (actual) control or manage but not merely the
right to control or manage. Control and management is situated at a place where the head, the
seat and the directing power are situated.
2 Non Resident:
AOP, BOI and Firms will be non - resident in India if control and management of its

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affairs is situated wholly outside India. These persons can only be either resident or not
resident but not ordinarily residents as depicted in the following diagram:

MISCELLANEOUS:
Following points are noteworthy:
A. Residential status for each previous year:
Residential status a person shall be determined for each previous year independently.

B. Different residential status for different assessment years:


Residential status of a person may change from previous year to previous year. Be
different for different assessment years and a person may have different residential status for
different assessment years. For instance, if a person leaves India for two years and then
comes back, he can be non - resident for those two years and resident for other years.

C. Resident in India and abroad:


A person may be resident in two or more countries at the same time. Conversely
in a particular assessment year, a person may be a non - resident in India as well as other
countries .
It is not necessary that a person, who is resident in India, will necessarily be non - resident
in all the other countries for the same assessment year. This is particularly true of a person,
who has changed his country two three times in a year and he does not fall in any category of
residents anywhere in the world.

D. Residence for all sources:

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If a person is a resident for one source of income in a previous year, he shall be deemed
to be a resident for all other sources of income also. [Section 6(5)]

(A) INCIDENCE OF TAX FOR DIFFERENT TAX PAYERS:


Tax incidence of different taxpayers is as follows
Individual and Hindu undivided family

Indian income

Resident and

Resident but not

Non-resident

ordinarily resident

Ordinarily

in India

in India

resident in India

Taxable in India

Taxable in India

Taxable in India

Taxable in India

Taxable in India

India Not taxable in

Foreign income
- If it is business income
and business is controlled

India

wholly or partly from


India
- If it is income from

Taxable in India

Taxable in India

Not taxable in India

Taxable in India

Not taxable in

Not taxable in India

profession which is set up


in India
- If it is business income

India

and business is controlled


from outside India
- If it is income from

Taxable in India
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Not taxable in

Not taxable in India

profession which is set up

India

outside India
- Any other foreign

Taxable in India

Not taxable in

Not taxable in India

India

income (like salary, rent,


interest, etc.)

Any other taxpayer (like company, firm, co-operative society, association of persons,
body of Individual, etc
Resident in India

Non-resident in India

Indian income

Taxable in India

Taxable in India

Foreign income

Taxable in India

Not taxable in India

7.1SCOPE OF TOTAL INCOME: (SEC-5):


Section 5 provides the scope of total income in terms of the residential status of the
assessee because the incidence of tax on any person depends upon his residential status.
The scope of total income of an assessee depends upon the following three important
considerations
(i)
(ii)
(iii)

The residential status of the assessee( as discussed earlier);


The place of accrual or receipt of income, whether actual or deemed; and
The point of time at which the income had accrued to or was received by or an
behalf of the assessee.

The admit of total income of the three classes of assessees would be as follows:
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1. Resident in India/ ordinarily resident in India:


A person is assessable to tax in respect of income which
i. Is received or deemed to be received in India by him or on his behalf
ii. Accrues or arises or deemed to accrue or arise to him in India
iii. Accrues or arises to him outside India

2. Resident but not ordinarily resident in India


A person is assessable to tax in respect of income which
i. Is received or deemed to be received in India by him or on his behalf
ii. Accrues or arises or deemed to accrue or arise to him in India
iii. Accrues or arises to him outside India from a business controlled in or profession set up in
India.

3. Non-resident in India
A person is assessable to tax in respect of income which
i. Is received or deemed to be received in India by him or on his behalf
ii. Accrues or arises or deemed to accrue or arise to him in India
Other points:
Received in India means first receipt in India. If an income is received first outside India
and then subsequently remitted to India, it shall be treated as received outside India.
Past untaxed profits shall not be considered to be income of the current year in any case.
Particulars of Income

ROR

RNOR

NR

Income received or deemed


to be received in India

Taxable

Taxable

Taxable

Income accrue or arises or


deemed to accrue or arises in
India

Taxable

Taxable

Taxable

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Income earned outside India

Taxable

Taxable (only which


earned
from
business/profession
controlled from India)

Category.
1) Resident & Ordinarily Resident
2) Resident & Not Ordinarily
3)Resident in India (RNOR)

is
a

Not
Taxable

Taxed in India
World Income.
Indian Income.
Income from business
Outside India controlled
From India.

4) Non-Resident.

Indian Income.

7.2RECEIPT AND ACCRUAL OF INCOME:


Income which is received in India or which accrues or arises in India is taxable in all cases.
The following points will help you to understand the concepts of receipt and accrual:
(1) Receipt and Remittance:
Receipt of income means the first occasion when the money comes under the control
or possession of the receiver. After the first occasion of receipt, if money is sent to
another place it is a mere remittance of money and not receipt of income
.
(2) Cash and Kind:
Income may be received in cash or in kind. For example a Doctor may receive a car in
lieu of fees from a rich patient; this would be receipt of income in kind and taxable.
When income is received in kind, amount of income is taken to be equal to the fair
market value of the item on the date of receipt.

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(3) Receipt by Assessee or On His Behalf:


Income directly received by the assessee is no doubt taxable in his hands. But income
received on behalf of the assessee by another person is also taxable in his hands. Thus
income received on behalf of the assessee by his agent or his bankers is taxable in his
hands. If the income is paid to (or diverted to) a third party, under instructions from
the assessee, such amount is also taxable in the hands of the assessee.
(4) Receipt and Accrual:
Income is said to be received when it reaches the assessee; on the other hand, when
the right to receive the income becomes vested in the assessee, income is said to be
accrue or arise. Thus accrual denotes right to receive any income, while receipt
denotes actual receipt of income. Generally, income must accrue first. Receipt
normally is after such accrual.
(5) Accrue and Arise:
Accrue refers to right to receive the income. Arise refers to the right to enforce
recovery of income.
(6) Accrued and Due:
For example, Salary accrues every day, but may becomes due on the last day of the
month.
(7) Method of Accounting:
Income arises when it is shown as income in books. If the assessees accounts are
maintained on mercantile basis, income is taxable when it accrues or arises. If the
assessees accounts are maintained on cash basis, income is taxable when it is actually
received. However, this is subject to the specific provisions of the Act. Thus the Act
provides that salary is taxable on accrual or receipt whichever is earlier, irrespective
of the method of accounting followed by the assessee.
(8) Deemed Receipt / Accrual:
Receipt or accrual may be actual or deemed. However, income accruing outside India
will not be deemed to be received in India merely because it is included in a balance

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sheet prepared in India (Explanation 1 to S.5). Further, once an income is included in


the total income of a person on the basis of accrual, it cannot be included again on the
basis of its receipt in subsequent period (Explanation 2 to S.5)

7.3INCOME DEEMED TO BE RECEIVED (SEC. 7)


As per Section 7, the following incomes are included in the scope of total income even if they
are not actually received in India:

1. Annual accretion to the credit balance of an employee in the case of recognized


provident fund to the extent provided under rules.
2. Excess contribution of employer in the case of recognized provident fund to the extent
as provided in the rules.
3. Transfer balance to a recognized provident fund from unrecognized provident fund to
the extent as provided under the rules.

7.4INCOME DEEMED TO ACCRUE OR ARISE (SEC.9):


As per Section 9, which is a deeming section,, certain incomes are deemed to accrue or
arise in India even though they may actually accrue or arise outside India. These incomes are
given below:
1. All incomes accruing or arising whether directly or indirectly through or from a.
b.
c.
d.

Any business connection in India or


Any property in India or
Any asset or any source of income in India or
The transfer of a capital asset situated in India.

Exceptions: No income is deemed to accrue or arise in following cases :


I.

Purchase of goods India by a Non resident for Export


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II.

Collection of news by a non - resident running a new agency , or publishing

III.

newspapers, magazines or journals


Shooting of film in India by a non - resident foreign citizen individual or a

IV.

company or firm in which no Resident Indian citizen is a partner or shareholder


Indian Income to be taken pro rata if all operations of a business not carried in
India.

Explanation: The term business connection includes a person, who


I.

Holds or habitually exercises holds an authority to conclude contract on behalf of

II.

the non - resident, except for purchase of goods or merchandises .


Has no such authority but maintains stock of goods and merchandise in India,
from which he regularly delivers stock or merchandise on behalf of the non -

III.

resident.
Secures orders in India for the non - resident and other non - resident, controlling,
controlled by or subject to the same common control as that of non - resident.

However, there will be no business connection as above if a non - resident carries on a


business through a broker, general commission agent or any other agent of independent
status, acting in ordinary course of business. For this purpose A broker, general commission
agent or an agent shall be deemed to be of an independent status if he does not work mainly
or wholly on behalf of the non - resident.

2. Salary earned in India i.e. salary payable for services rendered in India . It also includes
salary paid for the rest period or leave period preceded and succeeded by services rendered in
India and forms part of service contract of employment.

3. Salary received by Indian national from the government in respect of services rendered out
of India. However any allowance or any perquisite paid abroad is fully exempt from tax
under Section 10(7)

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4. Any dividend paid by an Indian company outside India..

5.Interet payable by the government or a resident person unless such interest is payable in
respect of borrowed funds used for a business or profession carried out of India, or by a non resident person on funds borrowed for the business or profession carried in India

6. Royalty payable by the government or a resident person unless such royalty is in respect of
any right of property or services utilised for a business or profession carried out of India for
the purpose of earning any income out of India or by a non - resident person in respect of any
right of property or services utilised for the purpose of business or profession carried in India
or for the purpose of earning any income in India).

Exception:
(i)

Royaltys payable for the transfer of any data, drawings, etc. outside India or
imparting of information outside India under an approved agreement by the

(ii)

Central Government made before the 1st day of April, 1976.


Royalties paid In lump sum, by a resident for transfer of computer software,
supplied by a non - resident along with the computer or computer - based
equipment under a scheme duly approved by Government of India.

7. Fees for technical services payable by the government or a resident person unless such fees
are payable in respect of services utilised in a business or profession for earning any income
out of India or by a non - resident person for services utilised in a business or profession
carried on by him in India or for earning any income from any source in India..

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Exception: fees are payable under agreement made before the 1st day of April, 1976 and
approved by the Central Government.
The income of a non - resident is deemed to accrue or arise in India under any of the above
clauses, shall be included in the total income of the non - resident, whether or not, the non resident has -

(i)
(ii)

a residence or place of business or business connection in India; or


Has rendered services in India.

ILLUSTRATION:
Mr. Mannu had the following incomes during the previous year ended 31st March, 2013:
(1)
(2)
(3)
(4)
(5)
(6)

Particulars
Professional fees received in India for three months
Payment for the services rendered in India
Income from business in Bangladesh, being controlled from India
Income from agriculture in Indonesia
Interest received in Paris in respect of securities in French companies
Amount brought into India out of the past untaxed profits earned in

Amount
18,000
16,000
14,000
12,000

Germany
10,000
8,000

You are required to compute his Total income, if he is :


(i)
(ii)
(iii)

a resident and ordinarily resident (ROR)


a resident but not ordinarily resident (NOR)
a non resident (NR).

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SOLUTION:
NAME OF THE ASSESSEE: Mr. MANNU.
PREVIOUS YEAR

: 2012-13.

ASSESSMENT YEAR

: 2013-14.

COMPUTATION OF TOTAL INCOME

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Item of income
1. Professional fees.
2. Received in U.K for

Nature of income
Income received in India

ROR
18,000

NOR
18,000

NR
18,000

Income accuring in India

16,000

16,000

16,000

Foreign Income

14,000

14,000

Nil

Foreign Income

12,000

Nil

Nil

Foreign Income

10,000

Nil

Nil

Remittance; not income

Nil

Nil

Nil

70,000

48,000

34,000

services in India.
3. Income from businesses in
Bangladesh, controlled
from India.
4. Income from agriculture
in Indonesia.
5. Interest received in Paris
on French securities.
6. Amount brought in India
out of past profits.

TOTAL INCOME

8.1REFERENCE:
www.indialiaison.com/residential_status.htm
www.du.ac.in
taxguru.in
220.227.161.86/18879sm_dtl_finalnew_cp2.pdf
ww.wiziq.com
www.mu.ac.in

and

26

from the dierct tax text book by Dr. Varsha. M. Ainapure.

27

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