Mr. Rohan furnished the following particulars of his income for the year ended 31.3.2025. Particulars ₹ (a) Income earned from business in Iran…

(a) Computation of gross total income of Mr. Rohan for the A.Y. 2025-26 Particulars Resident & ordinarily resident ₹ Resident but not ordinarily resident ₹ Non-Resident ₹ (a) Income earned from business in Iran, which is controlled from Delhi, out of which - 65,000 is received in India 80,000 80,000 65,000 (b) Pension for services rendered in India but received in Iran (Computed) 24,000 24,000 24,000 (c) Dividend received in Dubai from an Oil company, an Iran based company 15,000 - - (d) Interest on money borrowed by Mr. Deepender, a non-resident, for the purpose of investment in shares of XYZ Ltd., an Indian company 55,000 - - Gross Total Income 1,74,000 1,04,000 89,000 Notes: (a) As per section 5(1), global income is taxable in case of a resident. However, as per section 5(2), in case of a non-resident, only the following incomes are chargeable to tax in India: (i) Income received or deemed to be received in India; and (ii) Income accruing or arising or deemed to accrue or arise in India. Further, the income which accrues or arise outside India would be chargeable to tax in case of resident but not ordinarily resident in India, only if such income is derived from a business controlled in India. Accordingly, the entire income earned from business in Iran which is controlled from Delhi would be chargeable to tax in the hands of Mr. Rohan if he is a resident in India or resident but not ordinarily resident. However, if he is non-resident then only that part of income which is received in India would be taxable in his hands. (b) Dividend from an Iran based company, received in Iran and interest on money borrowed by Mr. Deepender, a non-resident, for the purpose of investment in shares of XYZ Ltd., an Indian company, would be taxable in the hands of Mr. Rohan, only if he is resident and ordinarily resident in India. If he is a resident but not ordinarily resident or a non-resident, the same would not be taxable in his hands in India since it has neither accrued nor arisen in India nor is it received in India.