CA Jasmeet Singh Arora 1

Residence & Scope of Total Income

Q.1 Mr. Sarthak, an individual and Indian citizen living abroad (Dubai), a tax haven, since
year 2005 and never came to India for a single day since then, earned the following
incomes during previous year 2023-24 :
Particulars Amount (in `)
(i) Income accrued and arisen in Dubai not taxable in 20,00,000
Dubai (being tax haven)
(ii) Income accrued and arisen in India 5,00,000
(iii) Income deemed to accrue and arise in India 8,00,000
(iv) Income arising in Dubai from a profession set up in 10,00,000
India
I. Determine the residential status of Mr. Sarthak and taxable income for the
previous year 2023-24 (assuming no other income arise during the previous year).
II. What would be your answer if income arising in Dubai from a profession set up
in India is ` 2 lakhs instead of ` 10 lakhs?
III. What would be your answer, if Mr. Sarthak born in Dubai and his parents were
born in India? (PYP NOV 2022)

Sol. : 1
Mr. Sarthak is an Indian citizen living in Dubai since 2005 who never came to India for
a single day since then, he would not be a resident in India for the P.Y. 2023 -24 on the
basis of number of days of his stay in India as per section 6(1).
However, since he is an Indian citizen
- having total income (excluding income from foreign sources) of ` 23 lakhs, which
exceeds the threshold of ` 15 lakhs during the previous year; and
- not liable to tax in Dubai,
he would be deemed resident in India for the P.Y. 2023-24 by virtue of section 6(1A).
A deemed resident is always a resident but not ordinarily resident in India (RNOR).

Computation of Total Income for A.Y.2024-25

Particulars `
(i) Income accrued and arisen in Dubai (not taxable in case -
of an RNOR)
(ii) Income accrued and arisen in India (taxable) 5,00,000
(iii) Income deemed to accrue or arise in India (taxable) 8,00,000
 CA Jasmeet Singh Arora 2

(iv) Income arising in Dubai from a profession set up in

India would be taxable in case of RNOR 10,00,000
Total income 23,00,000
II. If income arising in Dubai from a profession set up in India is ` 2 lakhs instead of ` 10
lakhs, his total income (excluding income from foreign sources) would be only 15 lakhs.
Since the same does not exceed the threshold limit of ` 15 lakhs, he would not be
deemed resident. Accordingly, he would be non-resident in India for the P.Y. 2023-24
and hence, his total income would be only ` 13 lakhs (aggregate of (ii) and (iii) above
i.e., ` 5 lakhs + ` 8 lakhs).
III. If Mr. Sarthak is born in Dubai and his parents were born in India, he would not be an
Indian citizen, but he may qualify as person of Indian origin. In such case, the provisions
relating to deemed resident would not apply to him.
Accordingly, he would be non-resident in India during the P.Y. 2023-24 and his total
income would be `13 lakhs.

Q. 2 Mrs. Shruti is an Indian citizen, is currently in employment with an overseas company

located in UAE. During the previous year 2023-24 , she comes to India for 157 days. She
is in India for 200 days, 100 days, 76 days and 45 days in the financial years 2019-20, 2020-
21, 2021-22 and 2022-23, respectively. Her annual income for the previous year 2023-24
is as follows:
Particulars Amount (`)
Income from salary earned and received in UAE 2,00,000
Income earned and received from a house property situated in UAE 5,00,000
Income deemed to be accrued and arise in India 5,00,000
Income from retail business (accrued and received outside India, 10,00,000
controlled from India)
Income accrued and arise in India 3,00,000
Life insurance premium paid by cheque in India 1,50,000
Determine the residential status of Mrs. Shruti for the assessment year 2024-25.
(Support your Answer with computation) (PYP MAY 2022)

Sol. : 2
Mrs. Shruti is an Indian citizen in employment in UAE. She comes on a visit to India
during the P.Y.2023-24 for 157 days.
Her stay in India in the four immediately preceding previous years is as follows :
P.Y. No. of days
P.Y.2019-20 200
P.Y.2020-21 100
 CA Jasmeet Singh Arora 3

P.Y.2021-22 76
P.Y.2022-23 45
Total 421
Computation of Total Income of Mrs. Shruti (excluding income from foreign sources)
Particulars `
Income from salary earned and received in UAE (income from a -
foreign source, hence, to be excluded)
Income earned and received from a house property situated in -
UAE (income from a foreign source, hence, to be excluded)
Income deemed to accrue or arise in India 5,00,000
Income from retail business (to be included since the business is 10,00,000
controlled from India, even though such income accrues and is
received outside India)
Income accrued and arising in India 3,00,000
18,00,000
Less: Deduction u/s 80C (LIC premium paid by cheque in India) – 1,50,000
Assuming other conditions are fulfilled
Total income (excluding income from foreign sources) 16,50,000
Mrs. Shruti, an Indian citizen visiting India in the P.Y.2023-24 , would be a
resident in India for A.Y.2024-25, if she satisfies either of the following
conditions -
(i) She is in India for 182 days or more during the P.Y.2023-24 or
(ii) She is in India for a period of 120 days or more during the P.Y.2023-24 and
her stay in India in the four immediately preceding previous years is 365
days or more.
[This condition will apply to her since she comes on a visit to India during
the previous year 2023-24 and her total income (excluding income from
foreign sources) is ` 16.50 lakhs, which exceeds the threshold of ` 15 lakhs]
This first condition is not satisfied since she is in India only for 157 days during the
P.Y.2023-24.
The second condition is satisfied, since she has stayed in India for 157 days during
the P.Y.2023-24 and 421 days in the four immediately preceding previous years.
Since she has become resident in India for A.Y.2024-25 by satisfying this
condition, by default, she
would be treated as resident but not ordinarily resident.
Conclusion – Mrs. Shruti’s residential status for A.Y.2024-25 is resident but not
ordinarily resident.
 CA Jasmeet Singh Arora 4

Note – The provisions of section 6(1A) deeming an Indian citizen to be a resident but
not ordinarily resident, irrespective of the period of her stay in India in the relevant
previous year, if she is not liable to tax in any other country would not apply to Shruti,
since she is a resident as per the provisions of section 6(1).

Q. 3 Mr. Jai Chand (an Indian citizen) left India for employment in country X on 5thJune,
2015. He regularly visited India and stayed for 60 days in every previous year since then.
However, in the financial year 2023-24, he did not come to India at all. He owns a
commercial building in Delhi which is let out. He has also set a retail store in India which
is controlled by his brother from India. He provides the following information to you
regarding his income for the financial year 2023-24:
Income from commercial building in Delhi - ` 12,00,000 (computed as per the provisions
of the Act).
Income from the retail store - ` 4,50,000 (computed as per the provisions of the Act)
Country X does not tax any individual on their income as there is no personal income-
tax regime there.
Determine the residential status of Mr. Jai Chand for the Assessment year 2024-25.
Will your answer change if he is a citizen of Country X? (PYP MAY 23)

Sol. : 3
Determination of residential status of Mr. Jai Chand for A.Y. 2024-25
Since Mr. Jai Chand, an Indian citizen employed in Country X, did not come to India at
all during the P.Y. 2023-24, he would not be a resident for A.Y.2024-25 as per section
6(1).
However, since he is an Indian citizen
- having total income (excluding income from foreign sources) of ` 16,50,000 [`
12,00,000, being income from commercial building in India + ` 4,50,000, being
Income from retail store in India], which exceeds the threshold of ` 15 lakhs
during the previous year; and
- not liable to tax in Country X, he would be deemed resident in India for the P.Y.
2023-24.
A deemed resident is always a resident but not ordinarily resident in India (RNOR).
Yes, in case Mr. Jai Chand is a citizen of Country X, he would be non-resident in India
for the P.Y. 2023-24, since the provisions of deemed resident are applicable only to an
Indian citizen

Q. 4 Mr. Prashant (aged 35 years) is an Australian citizen who is settled in Australia and visits
India for 125 days in every financial year since past 11 years. During the F.Y. 2023-24 , he
 CA Jasmeet Singh Arora 5

visited India for a total period of 200 days. The purpose of his visit was to meet his
family members who are settled in India and also for managing his family members
who are settled in India and also for managing his business in Sri Lanka through his
office in Chennai, India.
During the P.Y. 2023-24 , he has the following incomes:
(A) Income from business in Australia controlled form Australia - ` 20,00,000
(B) Income from business in Sri Lanka controlled form Chennai - ` 16,00,000
(C) Short-term capital gains on sale of shares of an Indian company received in
Australia - ` 50,000. The shares were sold online from Australia.
(D) Income from agricultural land in Australia, received there and then brought to
India - ` 2,00,000
Find out the residential status of Mr. Prashant and compute his total income for
Assessment Year 2024-25. (PYP MAY 2023)

Sol. : 4
Determination of Residential Status of Mr. Prashant
Mr. Prashant is an Australian citizen who comes on a visit to India for 125 days in every
financial year since the past 11 years. During the P.Y. 2023 -24, he visited India for 200
days. Since he stayed in India for 182 days or more during the P.Y. 2023-24, he would be
resident in India for the A.Y. 2024-25.
An individual is said to be “Resident and ordinarily resident [ROR]” in India in any
previous year, if he satisfies both the following conditions:
- He is a resident in at least 2 out of 10 previous years preceding the relevant
previous year; and
- His stay in India in the last 7 years preceding the relevant previous year is 730 days
or more [Refer Note 1 below for alternate presentation]

- First condition
- Residential status for P.Y.2022-23 (A.Y.2023-24) – Resident, since he has stayed in
India for ≥ 60 days (125 days) in the said P.Y. and ≥ 365 days ( 500 days, being 125
days x 4) in the four immediately preceding PYs.

- Residential status for P.Y.2021-22 (A.Y.2022-23) – Resident, since he has stayed in

India for ≥ 60 days (125 days) in the said P.Y. and ≥ 365 days ( 500 days, being 125
days x 4) in the four immediately preceding PYs.
- Therefore, he satisfies the first condition of being resident in India in atleast 2 out
of 10 previous years preceding the relevant P.Y
Second condition
Stay in India in 7 immediately preceding PYs = 7 x 125 days = 875 days > 730 days
 CA Jasmeet Singh Arora 6

Since both the conditions are satisfied, he is Resident and Ordinarily Resident (ROR).
In case of ROR, global income would be taxable in India. Accordingly, his total income
for A.Y. 2024-25 would as follows:
Computation of Total Income of Mr. Prashant for A.Y.2024-25

Particulars `
(i) Income from business in Australia 20,00,000
(ii) Income from business in Sri Lanka 16,00,000
(iii) Short-term capital gains on sale of shares of an Indian 50,000
company
(iv) Income from agricultural land in Australia [would not be
exempt, since it is not from an agricultural land in India] 2,00,000
Total income 38,50,000

Q. 5 Mr. Sanjay has following incomes during the previous year 2023 -24:
(1) Interest on England Development Bonds (1/3 received in India) ` 60,000.
(2) Interest received from a non-resident ` 5,000 against a loan given to him to run a
business in India.
(3) Royalty received from Akhil, a resident, for technical services given to run a
business outside India ` 20,000.
(4) Income from business in Sri Lanka ` 25,000 out of which ` 15,000 were received in
India. The business is controlled from India.
Compute taxable income of Mr. Sanjay for the assessment year 2024-25 if he is a
(I) Not ordinarily resident
(II) Non-resident (PYP NOV 23 )

Sol. : 5
Computation of taxable income of Mr. Sanjay for the A.Y. 2024-25
Not ordinarily Non-
resident (RNOR) resident
(1) Interest on England Development Bonds (1/3 20,000 20,000
received in India), amount of ` 20,000 being
received in India would be taxable in case of
both RNOR and non-resident.
 CA Jasmeet Singh Arora 7

(2) Interest received from non-resident against 5,000 5,000

a loan given to him to run a business in India
would be deemed to accrue or arise in India.
Thus, such interest is taxable in case of both
RNOR and non- resident
(3) Royalty received from Akhil, a resident for - -
technical services given to run a business
outside India would not be deemed to
accrue or arise in India, since such services
are utilised for business carried outside
India. Thus, royalty would not be taxable in
case of both RNOR and non-resident.
(4) Income from business in Sri Lanka of 25,000 15,000
` 25,000 out of which ` 15,000 were received
in India. Whole of the income from business
in Sri Lanka is taxable in case of RNOR, since
business is controlled from India. However,
in case of non-resident only the amount
received in India would be taxable.
Taxable Income 50,000 40,000

RTP
Q. 1 Miss Asha is an Indian citizen. She is a lawyer by profession. She started her
consultancy profession in India in 2020 with the name “New way associates”. In May
2022 , she got married to Mr. Ram, an American citizen. Mr. Ram came to India for the
first time on 1st May 2021 when he joined an MNC in India. He got a promotion and was
transferred to Dubai. He left for Dubai on 1st October, 2022 . Mrs. Asha accompanied
him to Dubai. She started providing consultancy there. Both of them came to India for
3 months from June to August in 2023 to spend time with Asha’s family. Following
incomes were earned by Mr. Ram and Mrs. Asha during the P.Y. 2023 -24.
1.Income of Mr. Ram `
1 Salary from company in Dubai (not liable to tax in Dubai) 13,00,000
2 Long term capital gain on sale of shares of an Indian company 2,50,000
3 Income from house property in Delhi (computed) 4,60,000
4 Dividend from shares of an Indian company 65,000
 CA Jasmeet Singh Arora 8

Income of Mrs. Asha `

1 Profit from consultancy profession in Dubai which was set up in India 12,00,000
(not liable to tax in Dubai)
2 Profit from consultancy profession in India 3,00,000
3 Long term capital gain on sale of shares of British company, credited 60,000
to her Dubai bank account
4 Short term capital loss on sale of listed shares of an Indian company (42,000)
Determine the residential status of Mr. Ram and Mrs. Asha and their total income for
the A.Y. 2024-25 ignoring the provisions of section 115BAC.
(RTP NOV 23)
Sol. : 1
Determination of residential status of Mr. Ram
Mr. Ram is an American citizen who comes on a visit to India during the P.Y. 2023-24
for 3 months. He has been in India from 1st May 2021 to 1st October 2022 . Since Mr.
Ram has been in India for a period of more than 60 days (i.e., 92 days) during the P.Y.
2023-24 and for a period of more than 365 days (i.e., 519 days) during the 4 immediately
preceding previous years, he satisfies one of the basic conditions and he is a resident
for the A.Y. 2024-25.
Since his period of stay in India during the preceding 7 previous years is less than 730
days (i.e., 519 days), he is a resident but not-ordinarily resident in India during the A.Y.
2024-25 .
Since Mr. Ram is a resident but not-ordinarily resident, income which accrues or arises
in India, deemed to accrue or arises in India, received in India, deemed to be received
in India and income derived from business controlled in or a profession set up in India
is chargeable to tax in India in his hands.
Computation of total Income of Mr. Ram for the A.Y. 2024-25
Particulars of income (`)
1 Salary from company in Dubai [Not taxable, since it accrues and -
arises outside India]
2 Long term capital gain on sale of shares of an Indian company 2,50,000
[Taxable, since it accrues and arises in India]
3 Income from house property in Delhi [Taxable, since it accrues 4,60,000
and arises in India]
4 Dividend from shares of an Indian company [Taxable, since it 65,000
accrues and arises in India]
7,75,000
Determination of residential status of Mrs. Asha
 CA Jasmeet Singh Arora 9

Mrs. Asha is an Indian citizen who comes on a visit to India during the P.Y. 2023 -24 for
3 months i.e., 92 days. Since she does not satisfy any of the basic conditions of staying
in India for 182 days or 120 days during the P.Y. 2023-24, she is not a resident in India as
per section 6(1).
Mrs. Asha would be a deemed resident under section 6(1A) if her total income other
than the income from foreign sources exceeds ` 15 lakhs during the P.Y. 2023-24 as she
is an Indian citizen and is not liable to tax in Dubai.

Q. 2 Mrs. Roma, an Indian Citizen, is a government employee working for the Indian
Government. She submits the following information for the previous year ending
31.03.2024:
`
1 Salary income received in Malaysia for services rendered there 2,00,000
2 Profit from business carried on in Orissa 80,000
3 Loss from business carried on in Baroda (20,000)
4 Profit from business carried on in Paris (income is earned and 42,000
received in Sydney and business is controlled from Paris)
5 Loss from business carried on in Canada (though profits are not (46,000)
received in India, business is controlled from Dehradun)
6 Unabsorbed depreciation of business in Canada 16,000
7 Profit from Indonesia business (controlled form Delhi) and 60% of 70,000
profit deposited in a bank in Indonesia and 40% received in India
8 Rent from house property situated in Canada and received in 1,92,000
Canada
Determine the gross total income of Roma for the A.Y. 2024-25 ignoring the provisions
of section 115BAC on the assumption that she is:
(1) Resident but not ordinarily resident in India
(2) Non-resident in India. (RTP MAY 23)

Sol. : 2
Computation of gross total Income of Mrs. Roma for the A.Y. 2024-25
Particulars of income Resident but not Non-
ordinarily Resident Resident
(`) (`)
1 Salary income received in Malaysia for 2,00,000 2,00,000
services rendered there (Note 1)
Less: Standard deduction under section 16(ia) 50,000 50,000
1,50,000 1,50,000
 CA Jasmeet Singh Arora 10

2 Profit from business carried on in Orissa 80,000 80,000

[Since it accrues or arises in India]
3 Loss from business carried on in Baroda (20,000) (20,000)
[Since it accrues or arises in India]
4 Profit from business carried on in Paris Nil Nil
(income is
earned and received in Sydney and business
is
controlled from Paris) [Since it accrues or
arises
outside India]
5 Loss from business carried on in Canada (46,000) Nil
(business is controlled from Dehradun)
6 Unabsorbed depreciation of business in (16,000) Nil
Canada
7 Profit from Indonesia business (business is 70,000 28,000
controlled from Delhi)
8 Rent from property situated in Canada and Nil Nil
received in Canada
Gross Total Income 2,18,000 2,38,000
Note 1 - Income from “Salaries” payable by the Government to a citizen of India for
services rendered outside India is deemed to accrue or arise in India as per section
9(1)(iii). Standard deduction under section 16(ia) is allowable, irrespective of
residential status.
Note 2 – In case of a non-resident, only income received or deemed to be received in
India and income accruing or arising or deemed to accrue or arise in India is chargeable
to tax. However, in case of a resident but not ordinarily resident, income derived from
a business controlled in or profession set up in India is also taxable even though it
accrues or arises outside India.
Therefore, income referred to in S. No. 1, 2 and 3 are taxable in the hands of Mrs. Roma
in both cases if she is a resident but not ordinarily resident or if she is a non-resident.
Loss from business carried on in Canada, unabsorbed depreciation of business in
Canada and Profit from Indonesia business would be fully chargeable to tax in India if
she is a resident but not ordinarily resident as it derived from a business controlled in
India. However, Profit from Indonesia business is taxable in case of non-resident to the
extent of such profits received in India.

Q. 3 Mr. Dhanush, an Indian citizen aged 35 years, worked in ABC Ltd. in Mumbai. He got a
job offer from XYZ Inc., USA on 01.06.2022. He left India for the first time on 31.07.2022
and joined XYZ Inc. on 08.08.2022. During the P.Y. 2023-24, Mr. Dhanush visited India
from 25.05.2023 to 22.09.2023. He has received the following income for the previous
year 2023-24 –
 CA Jasmeet Singh Arora 11

Particulars `
Salary from XYZ Inc., USA received in USA 7,00,000
Dividend from Indian companies 5,50,000
Agricultural income from land situated in Punjab 55,000
Rent received/receivable from house property in Lucknow 4,00,000
Profits from a profession in USA, which was set up in India, received 6,00,000
there
Determine the residential status of Mr. Dhanush and compute his total income for the
A.Y. 2024-25 (RTP NOV 2022)

Sol. : 3
As per section 6(1), an Indian citizen or a person of Indian origin who, being outside
India, comes on a visit to India would be resident in India if he or she stays in India for
a period of 182 days or more during the relevant previous year in case such person has
total income, other than the income from foreign sources, not exceeding ` 15 lakhs.
However, if such person has total income, other than the income from foreign sources,
exceeding ` 15 lakhs, he would also be a resident if he has been in India for at least 120
days during the relevant previous year and has been in India during the 4 years
immediately preceding the previous year for a total period of 365 days or more. In such
a case, he would be resident but not ordinarily resident in India.
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)
and which is not deemed to accrue or arise in India.
In this case, total income, other than the income from foreign sources, of Mr. Dhanush
for P.Y. 2023-24 would be
Particulars Amount
(`)
Salary from XYZ Inc., USA received in USA (Not included in total -
income, since it is income from foreign source)
Dividend from Indian companies (Included in total income, since 5,50,000
deemed to accrue or arise in India)
Agricultural income from land situated in Punjab [Exempt u/s 10(1)] -
Rent received/receivable from house property in 4,00,000
Lucknow (Included in total income, since deemed to
accrue or arise in India)
Less: 30% of ` 4 lakhs 1,20,000 2,80,000
Profits from a profession in USA, which was set up in India, received 6,00,000
 CA Jasmeet Singh Arora 12

there
Total income, other than the income from foreign 14,30,000
sources
Since, Mr. Dhanush is an Indian citizen who comes on a visit to India only for 121 days
in the P.Y. 2023-24 and his total income, other than income from foreign sources does
not exceed ` 15 lakhs, he would be non-resident for the A.Y. 2024-25 .
A non-resident is chargeable to tax in respect of income received or deemed to receive
in India and income which accrues or arises or is deemed to accrue or arise to him in
India. Accordingly, his total income would be as follow –
Particulars Amount
(`)
Salary from XYZ Inc., USA received in USA (Not taxable, since it neither -
accrues or arises in India nor is it received in India)
Dividend from Indian companies (Taxable, since deemed to accrue or 5,50,000
arise in India)
Agricultural income from land situated in Punjab [Exempt u/s 10(1)] -
Rent received/receivable from house property in Lucknow 4,00,000
(Taxable, since it is deemed to accrue or arise in India)
Less: 30% of ` 4 lakhs 1,20,000 2,80,000
Profits from a profession in USA, which was set up in India, received -
there
Gross Total Income/ Total income 8,30,000

Q. 4 From the following particulars of income furnished by Mr. Ashutosh, aged 65 years,
pertaining to year ended 31.03.2024 , compute the total income for the A.Y. 2024-25, if
he is
(a) Resident and ordinarily resident
(b) Non-resident
Particulars Amount (`)
(i) Capital gain on sale of land in Jaipur to Mr. Ramesh, a non- 1,50,000
resident, outside India. The consideration is also received outside
India in foreign currency
(ii) Rent from property in Delhi, let out to a branch of a foreign 1,20,000
company. The rent agreement is entered outside India. Monthly
rent is also received outside India
(iii) Agricultural income from a land situated in Nepal, received in 55,000
Nepal
(iv) Interest on savings bank deposit in UCO Bank, Delhi 18,000
 CA Jasmeet Singh Arora 13

(v) Income earned from business in London which is controlled 60,000

from Delhi (` 35,000 is received in India)
(vi) Gift received from his daughter on his birthday 55,000
(vii) Past foreign taxed income brought to India 37,000
(viii) Fees for technical services rendered to Shine, Ltd., a foreign 12,000
company, for business outside India and received also outside
India
(RTP MAY 22)

Sol. : 4
Computation of total income of Mr. Ashutosh for the A.Y. 2024-25
Particulars Resident Non-
and resident
ordinarily (`)
resident
(`)
Capital gain on sale of land in Jaipur to Mr. Ramesh, a 1,50,000 1,50,000
non-resident, outside India and
received outside India
Rent from property in Delhi, received outside India [` 84,000 84,000
1,20,000 – 30% of ` 1,20,000 under section
24(a)]
Agricultural income from a land situated in Nepal, 55,000 -
received in Nepal
Interest on savings bank deposit in UCO Bank, Delhi 18,000 18,000

Income earned from business in London which is 60,000 35,000

controlled from Delhi
Gift received from daughter (Not taxable, since - -
daughter is a relative)
Past foreign taxed income brought to India (Not - -
taxable)
 CA Jasmeet Singh Arora 14

Fees for technical services rendered to Shine, Ltd., a

foreign company, for business outside India and
received also outside India 12,000 -
Gross Total Income 3,79,000 2,87,000
Less: Deduction under section 80TTB/80TTA
[Interest on savings bank account subject to a
maximum of ` 50,000/` 10,000] 18,000 10,000
Total Income 3,61,000 2,77,000
Notes –
1. In case of a resident and ordinarily resident, global income is taxable as per
section 5(1). However, as per section 5(2), in case of a non-resident, only the
following incomes are chargeable to tax:
(i) Income received or deemed to be received in India; and
(ii) Income accruing or arising or deemed to accrue or arise in India.
Therefore, agricultural income from a land situated in Nepal, income earned from
business in London which is controlled from Delhi, received outside India and
fees for technical services from a non-resident for business outside India is not
taxable in case of non-resident.
2. In case of a senior citizen, being a resident aged 60 years or more, interest upto
Rs 50,000 from saving account with, inter alia, a bank is allowable as deduction
under section 80TTB while in case of a non-resident, interest upto `Rs 10,000
from saving account with, inter alia, a bank is allowable as deduction under
section 80TTA.