‘Tax Incidence in Bri ‘The following table highlights the t Incidence in Brief ax incidence in brief : In Whether Taxable or Not Sete Ordinarily Not-ordinari- Non-resident 2 : ie resident ly resident Income received in India whether accrued or arisen in India ‘Yes “Yes Yes Income deemed to be received in India whether accrued or ‘Yes Yes ‘Yes arisen in India or outside India. Income accruing or arising in India whether received in India ‘Yes Yes Yes or outside India. Income deemed to accrue or arise in India whether received ‘Yes ‘Yes Yes in India or outside India, Income received and accrued or arisen outside India from a Yes ‘Yes No business controlled from India or a profession set-up in India. Income received and accrued or arisen outside India from a ‘Yes No No business controlled from outside India or a profession set-up outside India. Income received and accrued or arisen outside India from Yes No No any other source. Income accrued or arisen and received outside India in No No No earlier years but later on remitted to India during the pre- vious year, Past untaxed foreign income brought in India in the previous No No No year. llustration 14 The following are the incomes of Shri Ram Prasad for the Previous Year 2022-23 : (a) Profit from business in Iran received in India & 5,000; (b) Income from house property in Iran received in India t 500;(©) Income from house property in Pakistan deposited in a bank there & 1,000; @ Profits of business established in Pakistan deposited in a bank there & 20,000 (out of 20,000 a sum of 10,000 is brought into India)—this business is controlled from India; (e) Accrued in India but received in England % 2,000; (f) Profit earned from business in Kanpur & 6,000; (@ Income from agriculture in England—it is all spent on the education of children in London 5,000; and (a) Past untaxed foreign income brought into India during the previous year t 10,000. From the above particulars compute the gross total income of Shri Ram Prasad for the Assessment Year 2028.24 if Shri Ram Prasad is (i) Ordinarily resident, (ji) Not-ordinarily resident, and (iii) Non-resident.Ilustration 16 The following are the incomes of Shri Kishan Lal for the Previous ‘Year 2022-23 : . Income from agriculture in Pakistan Income from Salary received in India but the services were rendered in Iraq (Computed) . Income from a business carried on in India Dividend from a Domestic Company Income earned and received in Bangladesh from bank deposits there ’ Tneome from a business in Sri Lanka but controlled from India and remitted to India pe oR z 30,000 12,000 12,000 2,000 6,000 14,000 Compute Shri Kishan Lal’s gross total income for the Assessment Year 2023-24 ifhe is : (i) Ordinarily resident, (ii) Not-ordinarily resident, (iii) Non-resident.Mlustration 17 Following are the incomes of Shri Ratan Chand for the Previous Year 2022-28 : Income from Salary accrued and received in India (Computed) Profit of a hotel business at Melbourne Dividend declared in Perth but received in India Income from transfer of a long-term capital asset situated in India Interest on debentures of a company at Manchester, which was received in India Interest received from Shri Philip, a non-resident, on the loan provided to him for a business carried on in India Royalty received in Germany from Shri Kailash, a resident in India, for technical services provided for a business carried on in Germany . Fees from an Indian Company carrying on business at London for technical services rendered at London having been directly deposited by the company in his bank account in India Compute Shri Ratan Chand’s gross total income for the Assessment Year 2023-24, ifhe is : resident, (ii) Not-ordinarily resident, (iii) Non-resident. Solution oR ae 2 ox z 20,000 30,000 4,000 20,000 6,000 5,000 20,000 30,000 (i) OrdinarilyIllustration 18 ‘Mr. Prasad has furnished the following particulars for the Previous Year 2022-23. total income if he is a non-resident. 1 Salary for 3 months received in India (Computed) 2. Dividends received in Germany from British Companies out of which 3,000 were remitted to India 3, Income from business in Pakistan being controlled from India 4, Interest on savings bank deposits in State Bank of India 5. Amount brought to India out of past untaxed profit earned in Japan 6. Income from house property in India (Computed) Compute his gross <4 9,000 22,000 10,000 1,000 20,000 3,400Mlustration 20 Following ar the particulars of income of Shri Hari Narayan Arora for the Previous Year ended Sst March, 2023 : (i) Royalty received from Government of India % 24,000. (i) Income from business earned in Afghanistan % 25,000 of which % 15,000 were received in India. Business is controlled from India. (iii) Interest received from Shri Aditya Kumar, a non-resident, against a loan provided to him for a business carried on in India ¥ 5,000. (iv) Royalty received from Shri Al-Afnan, a resident, for technical services provided to run a business outside India & 20,000. (v) Income from a business in Jaipur & 40,000, this business is controlled from France. € 20,000 were remitted to France. Compute gross total income of Shri Hari Narayan Arora for the Assessment Year 2023-24. If he is : (a) Ordinarily resident of India; (b) Not-ordinarily resident of India and (©) Non-resident of India in previous year.flustration 21 From the following incomes which incomes are assessable in India if the assessee is (a) Ordinarily resident, (b) Not-ordinarily resident, and (c) Non-resident : 1. Income from business in Kolkata, managed in US.A., % 25,000. 2. Income from pension for services rendered in India, receivéd in London, ¢ 15,000 (Computed). 3. Income from assets in Burma, received in India, t 10,000. 4, Profit from business in Sri Lanka, deposited in a bank there, ¥ 15,000. 5. Income from profession in Kenya received there. The profession was set-up in India, % 15,000. 6. Interest on U.K. Government securities, half of which received in India, t 5,000. 7. Interest on England Development Bonds (1/5 received in India), ¢ 50,000. 8. Income from agriculture in America, received there, but later on remitted to India, 81,000. 9. Income from property in Canada, received outside India, ¢ 40,000. (0. Income earned from business in Uganda, which is controlled from Delhi ( 25,000 is received in India), = 45,000. 11. Profit on sale of a building in India but received in Sri Lanka, 18,000. 12. Salary received in India for services rendered in London, % 8,000 (Computed).13. Income earned and received in Bangladesh from bank deposits there, 6,000. 14. Income accrued in Bhopal but received in Singapore, ¢ 6,000. 15. Income from agriculture in England, it is all spent on the education of children in London, 5,Shankar, a foreign national, furnishes the following particulars of his income relevant for the Previous wr 2022-23 : z 1. Profit on sale of plant at London (one-half is received in India) 1,46,000 2. Profit on sale of plant at Delhi (one-half is received in London) 1,02,000 3. Salary from an Indian Company received in London (one-half is paid for rendering services in India) (Computed) 60,000 4, Interest on U.K. Development Bonds (entire amount is received in London) 40,000 5. Income from property in London received there 30,000 6. Profit from a business in Delhi managed from India 49,000 7. Income from agriculture in London received there, half of which is used for meeting hostel expenses of Shankar's son in England and remaining amount is later on remitted to India 25,000 8, Dividend (Gross) received in London from a company registered in India but mainly operating in U.K. 17,000 9, Income from a property in Nepal deposited by the tenant in a foreign branch of an Indian bank operating there 12,000 10. Gift from a relative in foreign currency (one-third of which is received in India and 3,70,000 remaining amount is used for meeting education expenses of Shankar's son in USA) Determine gross total income of Shankar for the Assessment Year 2023-24, if he is : (a) non-resident, ) resident but not-ordinarily resident, and (c) resident and ordinarily resident.Mlustration 24 ‘Shriram a foreign national, furnishes the following particulars of his income relevant for the Asses ment Year 2023-24 : : ‘Income from property in New York received there % 1,20,000. (a) (b) Income from business in Kolkata managed from Singapore @ 2,40,000. (c) Profit on sale of machinery in California (one-half. received in Kolkata) = 90,000. Dividend (Gross) received in Thailand from a company registered in India but mainly operat in Thailand & 15,000. Income from a house property in Dhaka deposited by the tenant there in a foreign branch of SBL & 36,000. Gift in foreign currency & 3,50,000 from a relative (one-half received in India and the balance used in New York). Income from agriculture in Myanmar % 45,000 received there. 1/3rd used while vis 2/8rd remitted later to Kolkata. (h) Income from profession (as a management consultant) in Philippines received there. The profession set up in India & 2,20,000. Compute his gross total income, if Shriram is : (a) Ordinarily resident, (b) Not-ordinarily resident, (c) Non-resident. ()Mlustration 25 Incomes of Mr. Y for the Previous Year 2022-23 are as follows : a Income from house property situated in India, received in Iran 30,000 Income from house property situated in Bhutan, received there 15,000 Interest on securities issued by Government of India, received in United States and spent there on education of children 60,000 Profit from business in Myanmar, which is controlled from India 70,000 Income from profession set up in India, half of which received in France 50,000 Gift received from father-in-law 10,000 Total gifts received from non-relatives 71,80,000 out of which & 1,20,000 received on the occasion of marriage of Mr. Y himself 1,80,000 Interest on Bonds issued by Government of Canada, received and spent there 15,000Pension from former employer in India, but received in United Kingdom 30,000 Pension from former employer in Spain but received in India directly 20,000 Compute the Gross ‘Total Income for the Assessment Year 2023-24, if he is Ordinarily resident or (ot-ordinary resident or Non-resident.