CA K Sanjay BhargavChartered Accountant
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NRI taxation under the Income-tax Act 2025

CA K Sanjay Bhargav, Chartered Accountant, Bengaluru

Membership No. 250054 · DISA (ICAI)

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Short answer: residency is still Section 6, unchanged in number and in substance. What moved is the NRI chapter (115C–115I → 212–218), treaty relief (90 → 159) and withholding on payments to non-residents (195 → 393(2)). Residential status still decides everything else.

Residency first — and it did not change

Section 6 keeps its number in the 2025 Act, and the tests are the ones you know:

  • 182 days or more in India during the year, or
  • 60 days in the year plus 365 days across the four preceding years

With the two refinements that have caused most of the recent disputes:

  • The 120-day rule for visiting NRIs whose Indian income exceeds ₹15 lakh — the 60-day limb tightens to 120 days
  • Deemed residency for an individual with Indian income above ₹15 lakh who is not liable to tax in any other country

RNOR — resident but not ordinarily resident — remains the transitional status most returning NRIs pass through, usually for about two years. It is worth planning for, because an RNOR is taxed on Indian-sourced income and on foreign income from a business controlled in India, but not on worldwide income. For someone returning with overseas investments or a foreign brokerage account, that distinction can be worth a great deal, and it turns on day counts.

Provision1961 Act2025 Act
Residence in Indias.6s.6 (unchanged)
Scope of total incomes.5s.5
Income deemed to accrue in Indias.9s.9

The charging architecture is deliberately untouched. A non-resident is taxed on income sourced in or received in India; deemed accrual — business connection, significant economic presence, royalty and fees for technical services, indirect transfer — continues at Section 9.

What did move

Provision1961 Act2025 Act
DTAA relief / TRCss.90, 90As.159
Unilateral relief (no treaty)s.91s.160
NRI concessional chapterss.115C–115Iss.212–218
Reinvestment exemptions.115Fs.215
Non-resident dividends, royalty, FTSs.115As.207
TDS on payments to non-residentss.195s.393(2)
Lower / nil deduction certificates.197s.395
Non-resident presumptive regimesss.44B–44BBBs.61
Royalty / FTS where there is a PEs.44DAs.59
Agent of a non-residents.163s.306
Occasional shippings.172s.316

Treaty relief at Section 159. The mechanics are unchanged — a treaty position requires a Tax Residency Certificate from the other jurisdiction together with the prescribed declaration, and the treaty applies where it is more beneficial than the Act. Where no treaty exists, unilateral relief sits at Section 160.

The NRI chapter at 212–218. Concessional rates on investment income and long-term gains from specified foreign-exchange assets continue, as does the reinvestment exemption now at Section 215.

⚠️ Buying property from an NRI

This is the single most common and most expensive error in NRI-related transactions, and it falls on the buyer, not the seller.

Buying immovable property from a resident uses the ordinary property-purchase withholding route, with its ₹50 lakh threshold and a modest rate on the consideration.

Buying from a non-resident does not. It falls under the non-resident provision — Section 195 of the 1961 Act, now Section 393(2) — and deduction is on the full sale consideration, not on the gain, at the applicable rate, with no threshold at all.

Buyers who apply the resident route to an NRI seller under-deduct substantially and become assessee-in-default, with interest and penalty following. The seller's remedy for the over-withholding relative to actual gain is a lower-deduction certificate under Section 395 (the old Section 197), obtained before completion — not a refund claimed a year later.

From 1 October 2026, a resident individual or HUF buyer no longer needs a TAN for this deduction. That removes a procedural barrier; it does not soften the obligation. See TDS on property sale by an NRI.

Foreign asset disclosure is a separate question

Nothing in the renumbering changes this, and it is worth stating plainly because the two get conflated: disclosure of foreign assets is an obligation independent of whether any tax is due. Non-disclosure carries exposure under the Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act, 2015, regardless of the tax position.

For a returning NRI with an overseas account or vested shares acquired abroad, that exposure often long predates the return to India. Where earlier years were missed, FAST-DS 2026 is the disclosure window being opened to regularise them — at 60% of value rather than the 120% the Black Money Act charges, or a flat ₹1,00,000 on narrower facts.

And it is not confined to people who are resident today. Section 131(1)(a) of the Finance Act, 2026 defines the eligible assessee in two limbs, the second of which expressly covers a person who is non-resident or not ordinarily resident in the previous year, provided they were resident in India either in the previous year to which the foreign income relates, or in the previous year in which the asset was acquired. Someone who built up a foreign holding while resident and has since moved abroad is squarely within it. The Scheme has not yet commenced, so nothing can be filed for now.

For the mechanics of what goes where, see Schedule FA from your broker statement.

A practical order of work

  1. Count the days for each year in question and fix residential status — everything follows from this
  2. Identify the RNOR window if you are returning, and what it shelters
  3. Establish the treaty position and obtain the TRC where relevant
  4. Separate India-taxable income from foreign income that is outside the net
  5. Check withholding obligations on any Indian payer, especially on a property transaction
  6. Deal with foreign asset disclosure on its own terms, independently of the tax

For the sections beyond the NRI chapter, the old-to-new mapping is the quick reference. For which Act governs a given year, see tax year vs assessment year.

This is a working reference, not the statute. For anything you are filing or relying on, confirm the section text and any treaty article against the Act, the treaty or the department's official 1961-vs-2025 comparison utility.

Frequently asked questions

Has the residency test changed under the new Act?

No. Residency is at Section 6 of the Income-tax Act, 2025 — the same number it held in the 1961 Act, and the same tests. Presence of 182 days or more in the year, or 60 days in the year together with 365 days across the preceding four years. The 120-day rule continues for visiting NRIs with Indian income above ₹15 lakh, as does deemed residency for individuals with Indian income above ₹15 lakh who are not liable to tax anywhere else.

What is the RNOR status and why does it matter?

Resident but not ordinarily resident is a transitional category that a returning NRI usually passes through for two years or so. It matters because an RNOR is taxed in India only on Indian-sourced income and on foreign income derived from a business controlled in India — not on worldwide income. For someone returning with overseas investments, the difference between RNOR and ordinary residence in a given year can be substantial, and it turns on day counts that are worth planning rather than discovering.

Where did the NRI concessional chapter go?

Chapter XII-A of the 1961 Act, Sections 115C to 115I, is now Sections 212 to 218 of the 2025 Act. It continues to offer concessional treatment on investment income and long-term gains from specified foreign-exchange assets, together with the reinvestment exemption formerly at Section 115F, now Section 215.

How do I claim treaty relief now?

Under Section 159 of the 2025 Act, which replaces Sections 90 and 90A. The substance is unchanged: a treaty position needs a Tax Residency Certificate from the other country, supported by the prescribed declaration. Unilateral relief where no treaty exists is at Section 160, the old Section 91.

I am buying property from an NRI. What do I deduct?

This is the trap that catches most buyers. Buying from a non-resident does not use the ordinary property-purchase withholding route with its ₹50 lakh threshold. It falls under the non-resident provision — Section 195 of the 1961 Act, now Section 393(2) — and deduction is on the full sale consideration, not merely the gain, at the applicable rate. There is no threshold. From 1 October 2026 a resident individual or HUF buyer no longer needs a TAN for this, which removes a procedural barrier but not the obligation.

Does the new Act change what I must disclose about foreign assets?

The disclosure obligation is unchanged in substance, and it is separate from the tax. Foreign assets and accounts remain reportable, and non-disclosure carries exposure under the Black Money Act independently of any tax due. If earlier years were missed, the FAST-DS 2026 disclosure window is the route being opened to regularise them.

NRI, returning, or unsure of your residential status?

Send your travel dates for the years in question along with your income sources. Residential status, what is taxable in India, treaty relief and any withholding obligations are established in writing before anything is filed.

Related service: NRI Taxation