Key Takeaways: Analysing the provisions of Sec 6 Recent budget amendments of Finance Act, 2020 Residency provisions under DTAA Illustrations and Judicial Precedents

1. Who is a Resident and Non-
Resident in India ?
CA Divakar Vijayasarathy

2. Research
Credits
Harish Kumar
CA Jugal Gala

3. Legends used in the Presentation
ABOI Active Business Outside India
AOP Association of Persons
CDC Continuous Discharge Certificate
DTAA Double Taxation Avoidance Agreement
FY Financial Year
HUF Hindu Undivided Family
ITA Income Tax Act, 1961
POEM Place of Effective Management
PY Previous Year
RNOR Resident but Not Ordinarily Resident
ROR Resident and Ordinarily Resident

4. Presentation Schema
Introduction
Residential Status of
Individuals
Recent Budget
Amendments
Residential Status of
HUF
Residential Status of
Firms and AOP
Residential Status of
Companies
Residency under DTAA Judicial Precedents

5. Introduction

6. Introduction
The incidence of tax on any assessee depends upon his residential status under the ITA
The residential status of an assessee must be ascertained with reference to each PY
The term residential status has been coined under the income tax laws of India and must not
be confused with an individual’s citizenship in India
The residential status of different types of persons viz an individual, a firm, a company etc. is
determined differently

7. Classification
The taxpayers are classified intro 3 broad categories on the basis of
residential status which are as follows:
Resident and ordinarily resident
Resident but not ordinarily
resident
Non-resident

8. Overview
Residential Status
Individual/ HUF Firm/ AOP/ Company etc.
Resident Non-resident
Resident and
ordinarily resident
Resident but not
ordinarily resident
Resident Non-resident

9. Taxability
Source of Income ROR RNOR Non resident
Indian Income Taxable (as per Sec
5(1)(a) & Sec 5(1)(b)) –
world income is taxed
Taxable (as per Sec
5(1)(a) & Sec 5(1)(b))
– India has primary
right to tax
Taxable (as per Sec
5(2)(a) & Sec 5(2)(b)) -
India has primary
right to tax
Foreign Income
1. Income earned/received or deemed to be
earned/received outside India from a business
controlled from or profession setup in India
Taxable (as per Sec
5(1)(a) & Sec 5(1)(b)) –
world income is taxed
Taxable (as per
Proviso to Sec 5(1)) –
business established
in India
Not Taxable (the
country of residence
would have the right
to tax)
2. Income earned/received or deemed to be
earned/received outside India from business
controlled from or profession setup outside
India
Taxable (as per Sec
5(1)(a) & Sec 5(1)(b)) –
world income is taxed
Not Taxable
(business is
established in the
country of residence)
Not Taxable (the
country of residence
would have the right
to tax)
3. Non-Business Income earned/received or
deemed to be earned/received outside India
Taxable (as per Sec
5(1)(c)) – world income
is taxed
Not Taxable (income
neither earned nor
received in India –
no source present in
India)
Not Taxable (the
country of residence
would have the right
to tax)
Income accruing or arising outside India shall not be deemed to be received in India only for the fact that it is taken
into account in balance sheet prepared in India
Income which has been considered on the basis of accrual or arising shall not be again included on the basis of receipt

10. Residential Status for
Individuals

11. Residential Status
An individual is said to be a resident in India in any PY if he
satisfies any one of the following conditions
He has been in India during the PY for a total period of 182 days or more or
He has been in India during the 4 years immediately preceding the PY for a total
period of 365 days or more and has been in India for at least 60 days in the PY
An individual is considered as non-resident, if both the above conditions are
not satisfied then the individual is said to be non-resident
• The period of stay is not required to be continuous or active nor is it essential that the stay
should be at the usual place of residence, business or employment of the individual
• For the purpose of counting the number of days stayed in India, both the date of departure
as well as the date of arrival are considered to be in India
Note

12. Exceptions
The following categories of individuals will be treated as resident in India only if the period of
their stay during the relevant PY amounts to 182 days
Indian citizen, who leaves India during the relevant PY as a member of the
crew of an Indian ship or for purposes of employment outside India, or
Indian citizen or person of Indian origin engaged outside India in an
employment or a business or profession or in any other vocation, who
comes on a visit to India during the relevant PY
An Indian citizen and member of the crew of a ship, the period of stay in India shall, in respect of an
eligible voyage (Indian ship), shall not include
Rule 126 of Income Tax Rules
the period commencing from the date entered into the Continuous Discharge Certificate (CDC)
in respect of joining the ship by the said individual for the eligible voyage and
the date entered into the CDC in respect of signing off by that individual from the ship in
respect of such voyage

13. Eligible Voyage
A voyage undertaken by a ship engaged in the carriage of passengers or freight in
international traffic where –
(i) for the voyage having originated from any port in India, has as its destination any
port outside India; and
(ii) for the voyage having originated from any port outside India, has as its destination
any port in India

14. Ordinarily and Not-Ordinarily
Resident
• On ascertainment of an assessee as resident the next step would be to identify whether he is
ordinarily resident or not ordinarily resident
• Only individuals and HUF can be resident and ordinarily resident (ROR) or resident but not
ordinarily resident (RNOR) in India
• An individual is said to be a resident and ordinarily resident if he satisfies both the following
conditions:
He is a resident at least in any 2 out of the last 10 years
preceding the relevant previous year, and
His total stay in India in the last 7 years preceding the relevant
previous year is 730 days or more
If any one of the above condition is not satisfied then the individual shall be
considered as not ordinarily resident for the relevant PY (conditions for HUF is
discussed subsequently)

15. Clarifications
Where an employee of a multinational company in India, is sent on deputation abroad, has stayed
in India for less than 182 days during the previous year – he shall be regarded as a non resident
It is not mandatory for a person to be unemployed at the time of leaving India for the purpose of
employment outside India to fall within the ambit of the exceptions
“Employment” includes self employment like business or profession taken up by assessee abroad
Stay in territorial waters of India shall be treated as stay in India
Foreign tour on behalf of an Indian employer shall not be considered as employment outside
India
An Individual is said to be a Person of Indian Origin if he or either of his parents or any of his
grandparents were born in undivided India – Sec 115C. Grandparents include both maternal and
paternal grand parents
Undivided India refers to India prior to partition (partition of India and Pakistan). Indo- Pakistan
partition happened on 14th of August 1947

16. Illustration
 Mr. B, a Canadian citizen, comes to India during the PY 2019-20
 Details of his stay in India in PY 2019-20 and earlier years are as follows
Case
Year No. of days
2019-20 70
2018-19 150
2017-18 90
2016-17 60
2015-16 55
 Determine Mr. B’s residential status for the AY 20-21

17. Solution
 During the PY 2019-20, Mr. B was in India for 70 days and during the 4 years
preceding the PY he was in India for 355 days (55+ 60+ 90+ 150 days)
 Thus he does not satisfy the condition of Sec 6
 Therefore, Mr. B he is a non-resident for AY 20-21

18. Illustration
• AB de Villiers, a South African cricket player visits India for 100 days every financial
year for participating in IPL
• This has been his practice for the past 10 financial years
• Find out the residential status of AB de Villiers AY 2020-21
Case

19. Solution
• Period of stay during the PY – 100 days (condition of minimum stay of 60 days
satisfied)
• Period of stay during 4 preceding PY 400 days (100 days x 4) (condition of 365 days
is satisfied)
• Since he satisfies one of the basic conditions under Sec 6, he is a resident for the AY
• Period of stay during 7 preceding PY – 700 days (100 days x 7) (less than 730 days)
• Therefore, AB de Villiers is a resident but not ordinarily resident during the PY
2019-20

20. Illustration
• Mr. Anand is an Indian citizen and a member of the crew of a Singapore bound
Indian ship engaged in carriage of passengers in international traffic departing from
Chennai port on 6th June, 2019
• Determine the residential status of Mr. Anand with the help of the following details
Particulars Date
Date entered into the CDC in respect of joining the ship by Mr. Anand 6th June, 2019
Date entered into the Continuous Discharge Certificate in respect of
signing off the ship by Mr. Anand
9th December, 2019
Period of stay in India before PY 19-20 800 days
Case

21. Solution
• The period beginning from 06.06.2019 and ending on 09.12.2019, being the dates
entered into the CDC has to be excluded for computing the period of his stay in
India
• Accordingly, 187 days [25+31+31+30+31+30+9] have to be excluded from the
period of his stay in India
• Consequently, Mr. Anand’s period of stay in India during the PY would be 179 days
[366 - 187 days]
• Since his period of stay in India during the PY is less than 182 days, he is a non-
resident for AY 2020-21
• The second condition of 60 days in PY + 365 days in 4 preceding PYs shall not be
considered as the case fall within the exception (Indian citizen onboarding an
Indian ship as a member of crew)

22. Amendments to Residential Status
Visit by Indian origin person or Indian citizen
• Criteria for the number of days for person of Indian origin or citizen visiting India, shall be
reduced from 182 days to 120 days.
• However, the above shall be applicable if such assessee has total income other than the
income from foreign sources, exceeding Rs. 15 lakhs during the PY
• 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)
Deemed Resident
• An Indian citizen having total income (excluding income from foreign sources) exceeding Rs.
15 lakhs during the PY shall be deemed to be resident in India, if he is not liable to tax in any
other country or territory by reason of his domicile, residence, etc.
• The status of such person shall be of RNOR
Incorporation of additional condition for determining RNOR
• An Indian citizen or a person of Indian origin whose total income (excluding income from
foreign sources) exceeds Rs. 15 lakhs during PY and who has been in India for a period of 120
days or more but less than 182 days
• An Indian citizen who is deemed to be a resident as mentioned above
By virtue of Finance Act, 2020 the above amendments are applicable from AY 2021-22

23. Overview of Changes
Class of Individual
Total income (excluding
income from foreign
sources)
Minimum no. of days of stay in India
during the relevant year to be
considered as ‘Resident in India'
Whether liable to
pay tax in any
other country?
Residential Status if stay in
India is less than no. of days
mentioned in condition (b)
(a) (b) (c) (d)
Indian citizen going outside
India as a crew member or for
employment
Not exceeding Rs. 15 lakhs 182 days Yes Non-resident
Not exceeding Rs. 15 lakhs 182 days No Non-resident
Exceeding Rs. 15 lakhs 182 days Yes Non-resident
Exceeding Rs. 15 lakhs 182 days No Not ordinarily resident*
Indian citizen visiting India
Not exceeding Rs. 15 lakhs 182 days Yes Non-resident
Not exceeding Rs. 15 lakhs 182 days No Non-resident
Exceeding Rs. 15 lakhs 120 days (and 365 days in last 4 years) Yes Non-resident
Exceeding Rs. 15 lakhs 120 days (and 365 days in last 4 years) No Not ordinarily resident*
Any other Indian citizen (does
not visit India during the year)
Not exceeding Rs. 15 lakhs - Yes Non-resident
Not exceeding Rs. 15 lakhs - No Non-resident
Exceeding Rs. 15 lakhs - Yes Non-resident
Exceeding Rs. 15 lakhs - No Not ordinarily resident
Person of Indian origin visiting
India
Not exceeding Rs. 15 lakhs 182 days - Non-resident
Not exceeding Rs. 15 lakhs 182 days (and 365 days in last 4 years) - Not ordinarily resident*
Exceeding Rs. 15 lakhs 120 days (and 365 days in last 4 years) Yes Non-resident
Exceeding Rs. 15 lakhs 120 days (and 365 days in last 4 years) No Non-resident
*The period of stay in India should be 120 days or more but less than 182 days

24. Illustration
• Mr. A during the PY 2020-21 earned a total income of Rs. 30 lakhs
• Break-up of total income – Rs. 13 lakhs in Canada and Rs. 17 lakhs in India
• Through the existing provisions of taxation prevailing in Canada, Mr. A is not
taxable
• Determine the residential status of Mr. A for AY 2021-22 considering him as an
Indian citizen and not satisfying any of the conditions for residency under Sec 6
Case

25. Solution
 During the PY 2020-21 Mr. A (Indian citizen) earned a total income Rs.
17 lakhs which is derived in India
 He also earned an income of Rs. 13 lakhs in Canada which are not
taxable in the respective jurisdiction
 Since Mr. A being an Indian citizen having a total income of Rs. 17
lakhs in India and not taxable in any other country for his income
derived, Mr. A is deemed to be a resident but not ordinarily resident
for the PY 2020-21
Pre-Amendment
For the PY 2020-21 Mr. A will be considered as non-resident as it
does not satisfies any of the conditions mentioned under Sec 6
Post-Amendment

26. Illustration
 Mr. B is an Indian citizen
 He got employment in A Inc (US Company) and moved to USA during the
PY 2018-19
 However, Mr. B visits India for a period of 135 days during the PY 2020-21
 Also during PY 2020-21 he earned an income of Rs. 17 lakhs from India
 Determine the residential status of Mr. B for the AY 21-22
Case

27. Solution
Pre-Amendment
 As per Sec 6, an Indian citizen, employed outside India, who comes on a visit to
India in any PY shall be said as resident only if his duration of stay in the PY
exceeds 182 days
 In the given case, Mr. B (Indian citizen) visits India and stays only for a period of
135 days in the PY 2020-21 (less than 182 days)
 Thus, Mr. B is considered as non-resident for the AY 2021-22
 Duration of stay in India by Mr. B for the PY 2020-21 – 135 days
 Income earned by Mr. B in India for the relevant PY – Rs. 17 lakhs
 Therefore, the eligible period of stay to consider as non-resident – less than 120 days
as per the amendment
 Since Mr. B stays for a period of 135 days and earned income exceeding Rs. 15 lakhs
he shall considered as resident but not ordinarily resident for the AY 2021-22
Post-Amendment

28. Residential Status for HUF,
Firms and AOP

29. Residential Status of HUF
Residential Status
A HUF would be resident in India if the
control and management of its affairs
is situated wholly or partly in India
If the control and management of the
affairs is situated wholly outside India, it
would become a non-resident
Resident Non-Resident
Is Karta resident in India at least in any 2
PYs out of 10 PYs preceding the relevant PY
(+)
Is his stay in India for 730 days or more
during the 7 PYs preceding the relevant PY
HUF is ROR
HUF is RNOR
No
Yes
The expression control and management refers to
the central control and management and not to the
carrying on of day-to-day business by servants,
employees or agents
Further, it needs to be checked for every PY

30. Illustration
 The business of a HUF is transacted from Australia
 Mr. E, the Karta of the HUF, who was born in Kolkata, visits India during the PY
after 15 years
 He comes to India on 1.4.2019 and leaves for Australia on 1.12.2019
 During his stay, he controls and manages the affairs of the business of HUF
from India
 Determine the residential of the HUF for AY 2020-21
Case

31. Solution
 Mr. E (Karta) controls and manages the affairs of the HUF from India during his visit to
India
 HUF is said to be resident if the control and management of affairs is partially or
wholly situated in India
 Therefore, HUF is said to be resident during the PY 2019-20
 To determine HUF as ROR the Karta should be resident in India at least in any 2 PYs
out of 10 PYs preceding the relevant PY and his stay in India for 730 days or more
during the 7 PYs preceding the relevant PY
 Since the Karta doesn’t satisfies the conditions for ROR, HUF is considered as
Resident but non ordinarily resident

32. Residential Status of Firms and AOP
Resident
Residential Status
Non-Resident
A firm and an AOP would be resident in
India if the control and management of its
affairs is situated wholly or partly in India
Where the control and management of the
affairs is situated wholly outside India, the
firm and AOP would become a non-resident

33. Residential Status for
Companies

34. Residential Status of Companies
A company would be resident in India in any previous year, if
it is an Indian company or
its place of effective management (POEM),
in PY is in India
Place of effective management means a place where key management and
commercial decisions that are necessary for the conduct of the business of an
entity as a whole are, in substance made

35. POEM
Determination of the POEM will depend upon the facts and circumstances of a given case
The POEM concept is one of substance over form
Since “residence” is to be determined for each year, POEM will also be required to be determined
on year to year basis
The process of determination of POEM would be primarily based on the fact as to whether or not
the company is engaged in Active Business Outside India
The principles for determining POEM are not to be seen with reference to any particular moment
in time, rather the activities performed over a period of time, during the PY, need to be
considered
Further, where based on the facts and circumstances if it is determined that during the PY the
POEM is in India and also outside India then POEM shall be presumed to be in India if it has
been mainly /predominantly in India
Provisions of POEM needs to be checked only if turnover or gross receipts exceeds Rs. 50 crores
in a PY

36. Special Provisions for Foreign Company
resident in India – Sec 115JH
Where a foreign company is said to be resident in India in any PY and
such foreign company has not been resident in India in any of the PYs preceding the said previous year,
the provisions of this Act relating to the computation of total income, treatment of unabsorbed
depreciation, set off or carry forward and set off of losses, collection and recovery and special
provisions relating to avoidance of tax shall apply with such exceptions, modifications and
adaptations as may be specified in that notification (shall be laid before each House of Parliament) for
the said previous year
Provided that where the determination regarding foreign company to be resident in India has been
made in the assessment proceedings relevant to any previous year, then, the provisions of this sub-
section shall also apply in respect of any other previous year, succeeding such previous year, if the
foreign company is resident in India in that previous year and the previous year ends on or before
the date on which such assessment proceeding is completed.
For example- If A Inc is determined as a resident during the assessment of previous of year 2017-18,
which concluded on 01-06-2020, then the provisions of this section shall also apply to the succeeding
previous years 2018-19 and 2019-20 if the foreign company is resident in India during those years.

37. Withdrawal of Benefits
Where, in a previous year, any benefit, exemption or relief has been claimed and granted
to the foreign company u/s 115JH(1), and, subsequently, there is failure to comply with
any of the conditions specified in the notification issued u/ss(1), then,—
(i) such benefit, exemption
or relief shall be deemed to
have been wrongly allowed;
(ii) the AO may, notwithstanding
anything contained in this Act, re-
compute the total income of the
assessee for the said previous year and
make the necessary amendment as if
the exceptions, modifications and
adaptations referred to u/ss (1) did not
apply
(iii) the provisions of section 154 shall,
so far as may be, apply thereto and
the period of four years specified u/s
154(7) shall be from the end of the
previous year in which the failure to
comply with the conditions referred to
in ss (1) takes place

38. Residency under DTAA

39. Meaning
Any person will be considered as resident of Contracting State if he is liable to
pay tax on the grounds of
domicile- treating a specific country as
permanent home
residence
place of incorporation
place of effective management
A person may not be liable to tax on the ground of various exemptions and incentives
offered in the ITA. However, if the conditions for such exemption are not satisfied,
such person will be liable to pay tax in India
Liable to pay Tax

40. State Government and Political Sub-
division
The term resident of a country also includes
Local
Authority
Political
Subdivisions
State
government
Political subdivisions include counties, cities, towns,
villages, and special districts such as school districts,
water districts, park districts, airport districts, etc.
An administrative body in local
government is known as the local
authority

41. Dual Residency in Case of Individuals
• When an individual is considered as resident of both the countries as per
the respective domestic tax laws, then the question of double residence
arises
• In such cases tie-breaker rule needs to applied
Mr. A is in India for a period of 182 days and in Mauritius for a period of 183 days in the PY.
In this case, in accordance with the provisions of the Indian and Mauritius taxation laws,
Mr. A is a resident of both India and Mauritius.
Since Mr. A considered as resident in both the countries, tie breaker rule needs to be
applied to determine the residency (explained subsequently)
Illustration

42. Tie-Breaker Rule
Rule No. Particulars Brief of the rule
1 Permanent home The rule gives preference to the Contracting State in which the individual has
a permanent home available to him
Example: Where the individual has a permanent home in one Contracting
State and has only made a stay of some length in the other Contracting State.
2 Centre of vital
interests
If the individual has a permanent home in both Contracting States or does
not have a permanent home, rule 2 gives preference to the state with which
the personal and economic relations of the individual are closer, this being
understood as the centre of vital interests.
3 Habitual abode Habitual abode refers to the period of time a taxpayer spends in each
country. On the basis of the country where most time is spent, the
residential status may be determined
4 Nationality Nationality simply means the official right to belong to a particular country.
If the individual is a national of both Contracting states or of neither of them,
the competent authorities shall settle the difficulty by Mutual Agreement
Procedure
The above rules shall be followed chronologically

43. Dual Residency other than Individual
• In case of dual residency of persons other than individual, the residency is determined by the
competent authorities of both the Contracting States by mutual agreement and by considering the
place of effective management, the place of incorporation or constitution any other relevant factors
A Ltd is an Indian company. The directors are residents of Mauritius and the major strategic decisions are
made in Mauritius. Hence effectively, the control and management of the company is exercised in
Mauritius.
In the above case, by virtue of A Ltd being an Indian company, it becomes a resident of India
Also by virtue of the control and management being in Mauritius, the company is a resident of Mauritius in
accordance with the Mauritian income tax laws.
Hence in the given case, A Ltd becomes resident of both India and Mauritius leading to dual residence
To arrive the residential status of A Ltd., the competent authority shall determine through mutual
agreement
Illustration

44. Judicial Precedents

45. Avdesh Kumar v. Deputy Commissioner of
Income-tax,Circle-1, Ghaziabad [2018] 96
taxmann.com 340 (Delhi - Trib.)
• Assessee had shifted to Korea for purpose of employment and received
salary in Korea
• The assessee had stayed outside India for 247 days
• On scrutiny of Form 26AS it was found statement that his employer had
deducted TDS on entire income, i.e., salary received in India as well as in
Korea
• The Assessing Officer, added back the salary income earned in Korea as
income of the assessee, considering him as resident
Facts
Whether the assessee treated as resident of India for the relevant
previous year ?
Issues

46. Contd.
 On the basis of the Form 26AS the Assessing Officer made addition in
respect of the income earned by the assessee from his foreign employer
 It has been held that when a citizen of India leaves India for employment
abroad and stayed outside India for 182 days or more, then he becomes a
non-resident;
 The income received from services rendered outside India cannot accrue or
arise or deemed to accrue or arise in India and cannot be taxed in India
notwithstanding the fact that the same is credited in the bank in India or
TDS has been deducted on such income
 Thus, the assessee could not be treated as resident of India
Held

47. Additional Director of Income-tax v. Sudhir
Choudhrie [2017] 88 taxmann.com 570 (Delhi -
Trib.)
• During the year under consideration, the assessees had remitted monies from
outside India into their bank accounts and from these accounts, investments
were made by them as share capital in a company
• Assessee claimed that he was a person of Indian origin and 'being outside India'
he 'comes on a visit to India' as per Sec 6(1)(a) and the residency status should be
tested accordingly
• He claimed that he should be classified as non-resident as during the relevant
previous year he was in India for 171 days
• The Assessing Officer, was of view that the gravity of personal and economic
relationship of an assessee would be the guiding factor to decide as to whether
he can be said to be 'being outside India’ to make Sec 6(1) applicable
Facts
Whether the assessee shall be considered as resident ?
Issues

48. Contd.
 The legislative intention is in fact encouraging 'non-residents' to maintain
investments in India and still not losing the status of a 'non-resident’
 The Commissioner (Appeals) held that residential status of the assessee is to
be determined solely on the basis of number of days he is present in India
 It was held that other facts like 'economic presence' and 'legal presence' are
irrelevant as the same are not recognized by the provisions of section 6
 Therefore, it was concluded that the assessee is a non-resident for the
relevant previous year
Held

49. Mrs. Smita Anand, China v. AUTHORITY FOR
ADVANCE RULINGS (INCOME TAX), NEW
DELHI [2014] 42 taxmann.com 366 (AAR - New
Delhi)
• The applicant left India for the purpose of employment in China and her
stay in India in a particular year never exceeded 182 days
• The applicant returned to India after resigning from her employment in
China during the relevant previous year
• Her stay in the relevant previous year was 119 days
• She contended that her residential status should be treated as non-
resident in view of Explanation (b) to section 6(1)
• In the preceding 4 years, her stay was more than 365 days
Facts
Whether the applicant is considered as non-resident as per ITA ?
Issue

50. Contd.
 Explanation (a) to section 6(1)(c) is applicable only in a particular year when
a person leaves India
 In effect if a person leaves India in any particular year for the purpose of
employment outside India and if his/her stay in India in that particular year
is for a period or periods amounting in all to 182 days, his/her status will be
resident in India
 The assessee has come to India after leaving his employment outside India,
the Explanation (a) to section 6(1)(c) will not be applicable
 The total stay in India of the applicant for the preceding four years is for a
period amounting to more than 365 days and total stay in India for the
financial year is 119 days which is more than 60 days
 It was held that the applicant's case does not fall under Explanation (a) or (b)
to section 6(1)(c) and having fulfilled the requirements of section 6(1)(c) her
status will be resident in India
Held

51. Thank You!
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