2 Residential Status

Basics of Residential Status [RS]

1. Total income of an assessee cannot be computed unless we know residential status of the assessee during
the previous year.
2. RS is determined for each category of person separately.
3. RS always determined for P.Y. because we have to determine the total income of the previous year only.
4. It is calculated for every year because it may change year to year.
5. A person can be resident of more than one country for any P.Y
6. Citizenship of a country and residential status of that country are different concept.
7. Onus of Proof

Individual/company Burden lies on the Department

HUF, Firm, LLP Assumed that they are Resident, Onus that they are not resident is on them.

Other Assessee Is a question of Fact, it is the duty of assessee to provide all relevant fact.

Residential Status is Determined for

Individual 6[1]

HUF 6[2] Others 6[4]

Company 6[3]

www.vlearnclasses.com R.S. 2.1 CA Vijay Sarda 8956651954

Sec 6(1): Residential Status of Individual
A person can be either be
Resident
They would be treated as Resident
if satisfy any of following condition-
a) If they stay in India for 182 days
or more in PY
OR
b) Stays in India for 60 days in PY
AND 365 days in 4 Previous
Preceding years.
Further clasify into
ROR (Resident ordinary resident)
An individual may become a ROR in India if he
satisfy both the following conditions given u/s 6(1)
besides satisfying any one of the above mentioned
conditions:
a) he is a resident in atleast any 2 out of the 10 PYs
immediately preceding the relevant PY, and
b) he has been in India for 730 days or more during
the 7PYs immediately preceding the relevant PY.
www.vlearnclasses.com
# Exception to 6(1): The person shall be treated an resident if stays
in for 182 days or more or else remains Non Resident.
1. Person leaving India for Employment.
2. Ship crew member.
3. Person of Indian origin.
# Person of Indian Origin: A person is deemed to be of Indian
Non resident origin if he, or either of his parents or any of his grandparents,
was born in Undivided India. It may be noted that grandparents
include both maternal and paternal grand parents.
If an individual does not satisfy any of the
above basic condition in sec 6(1) # Rule 126 Computation of period of stay in India in certain cases:
An individual, being a citizen of India and a member of the crew of a
ship, the period of stay in India in respect of an eligible voyage shall
not include the period beginning from the date of joining till the date
of signing off as mentioned in the Continuous Discharge Certificate
under the Merchant Shipping Act, 1958.
“eligible voyage” shall mean a voyage undertaken by a ship engaged in
the carriage of passengers or freight in international traffic where-
> For the voyage having originated from any port in India, has as its
destination any port outside India; &
> For the voyage having originated from any port outside India, has as
its destination any port in India.
RNOR (Resident not ordinary resident)
An individual is RNOR in any PY if-
a) He has been a NR in india in 9/10 PYs preceding that year, or
b) He has during the 7 PYs preceding that year been in India for a period of, or periods
amounting in all to, 729 days or less
c) A citizen of India, or a person of Indian origin, having total income, other than the
income from foreign sources, exceeding 15,00,000 during the PY, who has been in India
for a period or periods amounting in all to 120 days or more but less than 182 days; or
d) A citizen of India who is deemed Resident as per Sec.6(1A)
Explanation -“Income from foreign sources” means income which accrues or arises outside
India (except income derived from a business controlled in or a profession set up in India.
R.S. 2.2 CA Vijay Sarda 8956651954
Residential Status of Indian citizen
Residential Status for Indian Citizen

Income upto ₹ 15 lakhs Beyond ₹ 15 lakhs

Indian citizen/Person of Indian Origin who

Indian citizen/Person of Indian Origin who
being outside India comes on a visit to India in
PY & total income (other than foreign income)
is 15lakh or less
- They would be treated as Resident if they stay
in India for 182 days or more in PY.
being outside India comes on a visit to India in
PY & total income (other than foreign income)
is exceeding 15lakh.
- They would be treated as Resident if satisy
any of following condition-
a) If they stay in India for 182 days or more in
PY OR

b) If the period of stay is 120 days or more

during the PY AND 365 days or more during
the 4yrs immediately preceding PY.

IC / PIO having income exceeding 15L & liability to tax in

another country
no Person treated as RNOR as per Sec 6(1A) & 6(6)
yes RS depends upon period of stay in India when he visit
India
- Upto 120 days - NR
- Exceeding 120 days but less than 182 days & 365 days
or more in 4 PPY -
RNOR [6(1) & 6(6)]
- 182 days or more
- Sec 6(1) - Resident
- Sec 6(6) - ROR or RNOR

Deemed Resident Sec.6(1A)

Sec 6(1A) - An individual, being citizen of India, (Anot PIO) having total income, other than the income
from foreign sources, exceeding 15,00,000 during the PY shall be deemed to be resident in India in that
PY, if he is not liable to tax in any other country / territory by reason of his domicile / residence / any
other criteria of similar nature
If a person is deemed Resident as per sec 6(1A) he shall be RNOR

Important Notes :
1.The residential status of the assessee should be determined for each year separately.
2. The stay may be anywhere in India and for any length of time at each place in cases where the stay in
India is at more places than one, what is required is the total period of stay should not be less than the
number of days specified in each condition.
3. While determining residential status, the day of leaving and returning to India should be considered as a
stay in India.

www.vlearnclasses.com R.S. 2.3 CA Vijay Sarda 8956651954

Sec 6(2): Residential Status of HUF

>

>
Resident Sec.6[2] Non-Resident

>

>
If Control & Management
If Control & Management
Wholly or partly
Wholly Situated
situated in India
Outside India

>
>

If Karta Satisfies If Karta do Not Satisfies

Section 6[6] Section 6[6]
>

>
Whole HUF ROR Whole HUF RNOR
# Only Individual & HUF can be ROR/RNOR, other person can be
Resident/NR.

Additional Conditions :
a) Karta of resident HUF should be resident in atleast 2/10 PY immediately preceding relevant PY.
b) Stay of Karta during 7 PY immediately preceding relevant PY should be 730 days or more.

Sec 6(4): Residential Status of Other Assessee

>

Resident Sec.6[4]
If Control & Management
>
Non-Resident
If Control & Management
Wholly or partly situated in India Wholly Situated Outside India

Sec 6(3): Residential Status of Companies

>
>

Indian Company Foreign Company

>
>
>

Always Resident POEM in India POEM outside India

Then Resident Then NR

Sec 6(3) - A company is said to be a resident in India in any P. Y. if—

(i) It is an Indian company; or
(ii) Its place of effective management, in that year, is in India.

Explanation - For the purposes of this clause "place of effective management" means a place where key
management and commercial decisions that are necessary for the conduct of business of an entity as a
whole are, in substance made.

www.vlearnclasses.com R.S. 2.4 CA Vijay Sarda 8956651954

Sec 5 Scope of Total Income & Tax Incidence
In order to understand relationship between residential status & Incidence it is necessary to understand
meaning if Indian & Foreign income.
Indian Income :
1. Received In India
2. Deemed to be Received in India [ Sec 7 & 8]
3. Accrued in India
4. Deemed to be accrued or arise in India [Sec 9]
Foreign Income :
Income is not received or not deemed to be received in India. Income which does not accrue or arise in
India.
Remittance of Income Past Foreign Untaxed income brought to India
Approved mode - Exempt in India Not Taxable in India
Unapproved Mode - Taxable In India

INCIDENCE OF TAX FOR INDIVIDUAL & HUF

Income ROR RNOR NR
Indian Taxable in India Taxable in India Taxable in India
Foreign Taxable in India Only two type of Foreign income is taxable Not Taxable
in India.[Refer Notes] in India

Note : Income from business/profession which is set up in India

Note: Bachoo
INCIDENCE OF TAX FOR OTHERS learn this table

Income Resident NR

Indian Taxable in India Taxable in India

Foreign Taxable in India Not Taxable in India

Deemed to Received or Accrued

>
>

Accrued In India [Sec.9]

Deemed to be received in India [Sec.7]
>

Sec. 9(1)(i). Income out of Business

>

A) Contribution made by the employer Connection.

to RPF beyond 12% of the salary
[Upto 12% Exempt] (Refer Salary)
B) Interest credited to Employee
beyond 9.5% p.a. (Ref Salary)
C) Transfer from URPF to RPF
D) Contribution to pension fund u/s
80CCD (Refer Salary)
Sec. 9(1)(viii). Capital Assets situated In India.
Sec. 9(1)(ii). Salary earned in India
Sec. 9(1)(iii).Salary from government to
an Indian citizen for services
Rendered outside India.
Sec. 9(1)(iv).Dividend from Indian Co.
Sec. 9(1)(v). Income from Interest payable
by specified person.
Sec. 9(1)(vi). Income from Royalty
Sec. 9(1)(vii). Income from Technical services. (FTS)
Sec. 9(1).Income from Property/Assets
situated In India.
Sec. 9(1). Income from transfer of
Gift by R to NR.

www.vlearnclasses.com R.S. 2.5 CA Vijay Sarda 8956651954

Sec 9(1)(ii) Salary Earned in India
Income which falls under the head “Salaries”. if it is earned in India, for services rendered in India.
Non- Resident
Services rendered in India
>

>
Salary earned from India > This salary is taxable in India.

Sec 9(1)(iii) Salary Earned outside India

Income chargeable under the head “Salaries” payable by the Government.
Mr. Tiger earned
Salary = Taxable in India

}
Appointed China Allowance
Exempt in
Sec no 10(7)
Indian Government Mr. Tiger Perquisite

Sec 9(1)(iv) Dividend from an Indian Company

A dividend paid by an Indian company outside India.

(Resident) (Non-Resident)
Invested in
>

>

Pays Dividend >This dividend is Taxable in India.

Sec 9(1)(v) Interest payable

If interest is payable to Non-Resident by:
a) Government
b) Resident ( For activities in India)
c) Non-Resident ( For carrying out business profession in India)
Notes:
1) If NR pays interest for activities other than business or profession in India such interest is not Taxable
to NR in India For Eg: If NR took loan from another NR for acquisition of property in India interest
payable on such loan shall not be taxable in India, unless such interest is received in India.
2) If a Resident pays interest to NR outside India for carrying out business or profession outside India
then such interest is not taxable to NR in India.

www.vlearnclasses.com R.S. 2.6 CA Vijay Sarda 8956651954

 Non-Resident

Indian Government

Resident

Pays interest to Non-Resident Such interest is Taxable in India.

Non-Resident

Explanation: If a NR banking company receives interest from his permanent establishment in India (for eg:
subsidary), such interest shall deemed to accrue or arise in India and for the purpose of tax such PE in India
shall be deemed to be a separate person and provision of the Act shall apply accordingly.

Sec 9(1)(vi) Royalty payable

If Royalty is payable to Non-Resident by:
a) Government
b) Resident ( For activities in India)
c) Non-Resident ( For carrying out business profession in India)
Notes:
1) If NR pays royalty for activities other than business or profession in India such royalty is not Taxable to
NR in India
2) If a Resident pays royalty to NR outside India for carrying out business or profession outside India then
such royalty is not taxable to NR in India.

Non-Resident

Indian Government

Resident

Pays Royalty to Non-Resident Such Royalty is Taxable in India.

Non-Resident

www.vlearnclasses.com R.S. 2.7 CA Vijay Sarda 8956651954

# Meaning of Royalty:
“Royalty means consideration including any lump sum consideration for ;
1)The transfer of all or any rights (including the granting of a license) in respect of a patent, invention,
model, design, secret formula or process or trade mark or similar property ;
2)The imparting of any information concerning the working of, or the use of, a patent, invention, model,
design, secret formula or process or trademark or similar property
3) The use of any patent, invention, model, design, secret formula or process or trade mark or similar
4)property ;The imparting of any information concerning technical, industrial, commercial or scientific
knowledge, experience or skill ;
The use or right to use any industrial, commercial or scientific equipment but not including the amounts
referred to in section 44BB;
The transfer of all or any rights (including the granting of a license) in respect of any copyright, literary,
artistic or scientific work including films or video tapes for use in connection with television or tapes for
use in connection with radio broadcasting, including consideration for the sale, distribution or exhibition
of cinematographic films; or The rendering of any services in connection with the activities referred to
in sub-clauses (i) to (iv), (iva) and (v).
Explanation 3: For the purposes of this clause, "computer software" means any computer programme
recorded on any disc, tape, perforated media or other information storage device and includes any such
programme or any customized electronic data.
Explanation 4: For the removal of doubts, it is hereby clarified that the transfer of all or any rights in
respect of any right, property or information includes and has always included transfer of all or any right
for use or right to use a computer software (including granting of a licence) irrespective of the medium
through which such right is transferred.

Explanation 5: For the removal of doubts, it is hereby clarified that the royalty includes and has always
included consideration in respect of any
(a) Right, property or information, whether or not -the possession or control of such right, property or
information is with the Payer;
(b)Such right, property or information is used directly by the payer;
(c) The location of such right, property or information is in India.
Explanation 6 - For the removal of doubts, it is hereby clarified that the expression "process" includes and
shall be deemed to have always included transmission by satellite (including up-linking, amplification,
conversion for down-linking of any signal), cable, optic fibre or by any other similar technology, whether
or not such process is secret;

www.vlearnclasses.com R.S. 2.8 CA Vijay Sarda 8956651954

 Sec 9(1)(vii) FTS (Fees for Technical Services)
If FTS is payable to Non-Resident by:
a) Government
b) Resident ( For activities in India)
c) Non-Resident ( For carrying out business profession in India)
Notes:
1) If NR pays FTS for activities other than business or profession in India such FTS is not Taxable to NR
in India
2) If a Resident pays FTS to NR outside India for carrying out business or profession outside India then
such FTS is not taxable to NR in India.
Explanation 2 Meaning of FTS - For the purposes of this clause, "fees for technical services" means any
consideration (including any lump sum consideration) for the rendering of any managerial, technical or
consultancy services (including the provision of services of technical or other personnel) but does not
include consideration for any construction, assembly, mining or like project undertaken by the recipient or
consideration which would be income of the recipient chargeable under the head "Salaries";

Non-Resident

Indian Government

Resident

Pays FTS to Non-Resident Such FTS is Taxable in India.

Non-Resident

Sec 9(1)(viii) Gift of Money

Income arising outside India to NR, being any sum of money (Being Gift), paid on or after the 5th day of
July, 2019 by a person resident in India is taxable in India.

Sec 9(1)(i) Business Connection

All income accruing or arising, whether directly or indirectly, through or from any business connection in
India, or through or from any property in India, or through or from any asset / source of income in India,
or through the transfer of a capital asset situate in India is taxable in India
Only so Much of the Income is Taxable in India as is attributable to activities in India.[i.e. only Income Accrued or
received In India ]

Business Connection What is Business Connection

Deemed Business Connection

Not a Business Connection

www.vlearnclasses.com R.S. 2.9 CA Vijay Sarda 8956651954

Explanation 2 - Meaning of business connection
It is hereby declared that "business connection" shall include any business activity carried out through a
person who, acting on behalf of the non-resident,-
(a) Has and habitually exercises in India, an authority to conclude contracts on behalf of the non-resident
or habitually concludes contracts or habitually plays the principal role leading to conclusion of contracts
by that non-resident and the contracts are—
(i) In the name of the non-resident; or
(ii) For the transfer of the ownership of, or for the granting of the right to use, property owned by that
non-resident or that non-resident has the right to use; or
(iii) For the provision of services by the non-resident; or

Contract for sale on Behalf

>

of Jaguar, in India, is Given to Non-Resident

TATA.

Resident Jaguar has Business Connection in India.

(b) Has no such authority, but habitually maintains in India a stock of goods or merchandise from which he
regularly delivers goods or merchandise on behalf of the non-resident; or

Jubliant maintain stock on

>

Behalf of Domino’s
Non-Resident

Resident Domino’s has Business Connection in India.

(c) Habitually secures orders in India, mainly or wholly for the non-resident or for that non-resident and
other non-residents controlling, controlled by, or subject to the same common control, as that non-resident:

Gada Electronics
GADA Electronics Secure
>

order on Behalf on MI
Non-Resident
Resident
MI has Business Connection In India.

# Provided that such business connection shall not include any business activity carried out through a
broker, general commission agent or any other agent having an independent status, if such broker, general
commission agent or any other agent having an independent status is acting in the ordinary course of his
business :
Burj Al Arab (Dubai)
MMT just act as Agent
>

It has Independent Status.

Non-Resident
Resident Burj Al Arab does not Have Business Connection in India

www.vlearnclasses.com R.S. 2.10 CA Vijay Sarda 8956651954

 Deemed Business Connection
It is hereby declared that the significant economic presence of a non-resident in India shall constitute
"business connection" in India and "significant economic presence" for this purpose, shall mean—
(a) Transaction in respect of any goods, services or property carried out by a non-resident with any person
in India including provision of download of data or software in India, if the aggregate of payments
arising from such transaction or transactions during the previous year exceeds 2crore. or

Amazon sold goods .

>

Non-Resident

If Amazons payments in aggrigate from India Exceed 2crore it will be

Resident deemed that Significant economic presence of Amazon is available In India
(b) Systematic and continuous soliciting of business activities or engaging in interaction with such number
of users in India, exceed 3crore.
>

Non-Resident

If Netflix user from India Exceed 3 lakh it will be deemed that Significant
Resident economic presence of Netflix is available In India
# The above transactions or activities shall constitute significant economic presence in India, whether or
not—
(a) The agreement for such transactions or activities is entered in India; or
(b) The non-resident has a residence or place of business in India; or
(c) The non-resident renders services in India:
Further that only so much of income as is attributable to the transactions or activities referred shall be
deemed to accrue or arise in India.

Not a business connection

In Following Cases there wont be any business connection if:
1. Activities are confined to Purchases In India for the purpose of Export.
2. A person engaged in the business of running a news agency or of publishing news papers, magazines
or journals, where activities which are confined to the collection of news and views in India for
transmission out of India;
3. No income shall be deemed to accrue or arise in India to such individual, firm or company through or
from operations which are confined to the shooting of any cinematograph film in India;
4. In case of a foreign company engaged in the business of mining of diamonds, if activities are confined
to the display of uncut and unassorted diamond in any special zone notified by the Central Government .

Circular 13/2017
Salary accrued to NR sea farer for service rendered outside India on a foreign going ship (with Indian
flag/not) shall be not included in Total Income nearly because the salary is credited in NRE a/c with
Indian Bank.

www.vlearnclasses.com R.S. 2.11 CA Vijay Sarda 8956651954

For Your Practice: Solved Questions
P. 1 Mr. A, an indian Citizen, is living in Mumbai since 1950, he left for China on July 1, 2017 and comes back
on August 7, 2022. determine his residential status for the AY 23-24.
Solution :
Stay in india for a minimum period of 182 days in the PY :
Mr. a has stayed in india for 237 (viz. 25 + 30 + 31 + 30 + 31 + 31 + 28 + 31) days in the PY 2022-23.
So, this test is satisfied.
So, Mr. a shall be a resident in india during the PY 2022-23. (AY 2023-24).
Keeping in view the facts of the given case, Mr. A satisfies the two additional conditions also namely :
He is resident in 2/10 PYs preceding the relevant PY.
PY Stay in PY (days) Stay during PY (days) Basic Con. satisfied Res / NR
2021-22 Nil - None Non-resident
2020-19 Nil - None Non-resident
2019-18 Nil - None Non-resident
2018-17 Nil - None Non-resident
2017-16 30+31+30+1= 92 365 days Second resident
2016-17 365 365 First resident
His stay in India is also more than 730 days in 7 PYs preceding relevant PY as he left for Japan on 1st July
2015.
PY Stay (days)
2021-22 Nil
2020-19 Nil
2019-18 Nil
2018-17 Nil
2017-16 92
2016-15 365
2015-14 366
total Stay in 7 PYs 823

Hence, Mr. a is resident and ordinary resident in India for the AY 2023-24

P. 2 Dr. B, an indian Citizen and a Professor in IIM, lucknow, left india on September 15, 2022 for USA to
take up Professors job in MIT, USA. Determine his residential status for the AY 2023-24.
Solution :
Dr. B being a citizen of india and who has gone out of the country for employment, will be governed
by 182 days test only and therefore the second condition under section 6(1), i.e. 60 days during relevant
PY shall not be applicable. Dr. B stayed in india for 168 (viz. 30 + 31 + 30 + 31 + 31 + 15) days only
in the relevant previous year. Hence, Dr. B shall be a non-resident in india for the AY 2023-24 as
condition by stay of 182 days in relevant PY is not satisfied.
P. 3 Mr. Anil, an Indian citizen, leaves India on 22nd September, 2022 for the first time to work as an
Engineer in France. Determine his residential status for AY 2023-24
Solution :
During the PY 2022-23, Mr. Anil, an Indian citizen, was in India for 175 days (i.e. 30+31+30+31+31+
22). He does not satisfy the minimum criteria of 182 days. also since he is an Indian citizen leaving
India for the purpose of employment outside India, the second condition u/s 6(1) is not applicable to
him. Therefore Mr. Anil is non-resident for the AY 2023-24.

www.vlearnclasses.com R.S. 2.12 CA Vijay Sarda 8956651954

P4. Examine the correctness or otherwise of the statement - “Income deemed to accrue or arise in India to
a non-resident by way of interest, royalty and fees for technical services is to be taxed irrespective of
territorial nexus”.
Solution:
This statement is correct.
As per Explanation to section 9, income by way of interest, royalty or fees for technical services which
is deemed to accrue or arise in India by virtue of clauses (v), (vi) and (vii) of section 9(1), shall be
included in the total income of the non- resident, whether or not -
(i) Non-resident has a residence or place of business or business connection in India; or
(ii) The non-resident has rendered services in India.
In effect, the income by way of fees for technical services, interest or royalty from services utilised in
India would be deemed to accrue or arise in India in case of a non-resident and be included in his total
income, whether or not such services were rendered in India and irrespective of whether the non-
resident has a residence or place of business or business connection in India.

Know Your Exams: Unsolved Questions

P. 1 Mr. R & Mr. S are brothers and they earned the following incomes during the FY Mr. R settled in
Canada in the year 2005 and Mr. S settled in Delhi. Compute the total income for the assessment year.

Particulars For R For S

Interest on Canada Development Bonds (only 50% of interest received in India) 35000 40000
Dividend from British company received in London 28000 20000
Profit from a business in Nagpur, but managed directly from London 100000 140000
Short term capital gain on sale of shares of an Indian company received in 60000 90000
India
Income from a business in Chennai 80000 70000

Fees for technical services rendered in India,but received in Canada 100000 -

Interest on savings bank deposit in UCO Bank, Delhi 7000 12000
Agricultural income from a land situated in GOA 55000 45000
Rent received in respect of house property at Bhopal 100000 60000
Life insurance premium paid - 30000

P. 2 Brett Lee, an Australian cricket player visits India for 100 days in every financial year. This has been
his practice for the past 10 financial years. Find out his residential status for the assessment year.
P. 3 Poulomi, a chartered accountant, is presently working in a firm in India. She has received an offer for
the post of Chief Financial Officer from a company at Singapore. As per the offer letter, she should join
the company at any time between 1st September, 2022 and 31st October, 2022. She approaches you for
your advice on the following issues to mitigate her tax liability in India:
(i) Date by which she should leave India to join the company;
(ii) Direct credit of part of her salary to her bank account in Kolkata maintained jointly with her mother
to meet requirement of her family
(iii) Period for which she should stay in India when she comes on leave.
P. 4 Mr. federer, NR residing in Sweden received rent from Mr. Nadal, NR in France in respect of property
taken in lease in Mumbai. As received outside India from NR, Federer claims that income not chargeable
to Tax in India.

www.vlearnclasses.com R.S. 2.13 CA Vijay Sarda 8956651954

P. 5 Mr. Shravan,citizen of India & employee of CG left India for first time on 11.02.2022 due to transfer to
Australia for assignment. He did not visit India any time during PY. From following particulars of his
income for FY 2022-23, compute his gross total income for A.Y. [N-16 RTP]
Particulars Rs.
Salary 6,10,000
Foreign Allowance (paid by the govt for rendering services in Australia 4,55,000
Interest on fixed deposit from bank in India 1,10,000
Income from agriculture in Malaysia 3,50,000
Income from house property in Malaysia 2,25,000

P. 6 Mr. Alok, Indian citizen & a member of crew of Singapore bound Indian ship engaged in carriage of
passengers in international traffic departing from Mumbai port on 6th June’22 From following details for
P.Y. determine S of Mr. Alok for AY assuming that his stay in India in the last 4 PY is 400 days & last
seven previous years is 750 days:
Date entered into CDC 6th June 2022
Date entered into signing off the ship 9th Dec 2022. [N-16 RTP]
P. 7 Mr. L & Mr. G are brothers & they earned following during PY Mr. L settled in Bangkok in 2006 &
Mr. G in Pune. Compute the total income
Particulars For L For G
Income from Profession in Bangkok (Setup In India received there 15000 -
Profit from Business in Pune but managed from Bangkok 40000 -

Rent (Computed) from property in Bangkok later on remitted to India 120000 -

Dividend from ABC ltd 5000 9000

Dividend from company in Bangkok received there 15000 8000
Income from Agriculture land is situated in Gujarat 7500 4000

Past foreign untaxed Income brought to India 5000 -

Fees for Technical Service rendered in India 25000 -

Income from Business in Pune (50% received In India) 12000 15000

P. 8 Gonikka provides you following, calculate total income if,she is ROR, RNOR, NR
Particulars ROR RNOR NR
Short term capital gain on sale of shares of Indian co received in
Germany Rs.15000
Dividend from Japanese company amount received in Japan 5000
Rent (Computed)from a property in London deposited in a bank in
London Rs.75000
Dividend from an India Company Rs. 6000
Agriculture income from Land in Gujarat Rs. 25000

Total Income

P. 9Miss Vivitha paid a sum of 5000 USD to Mr. Kulasekhara, a management consultant practicing in
Colombo, specializing in project financing. The payment was made in Colombo. Mr. Kulasekhara is a
Non-resident. The consultancy is related to a project in India with possible Ceylonese collaboration. Is
this payment chargeable to tax in India in the hands of Mr. Kulasekhara, since the services were used
in India? [SM]

www.vlearnclasses.com R.S. 2.14 CA Vijay Sarda 8956651954