A foreign national hockey player who is a non-resident in India, Mr. Robert Jonson, won 45 lakhs by competing in hockey competitions in India. In…

(i) Yes, the above income are subject to deduction of tax at source. Income referred to in section 115BBA (i.e., Participation in hockey tournaments in India and Contribution of an article relating to the sport of hockey in a sports magazine in India) is subject to deduction of tax at source@20% under section 194E. Income referred to in section 115BB (i.e., winnings from lotteries) is subject to deduction of tax at source@30% under section 194B. Since Mr. Mr. Robert Jonson, is a non-resident, the amount of tax to be deducted calculated at the prescribed rates mentioned above, would be increased by health and education cess@4%. (iii) Section 115BBA provides that if the total income of the non-resident sportsman or non-resident entertainer comprises of only income referred to in that section and tax deductible at source has been fully deducted, it shall not be necessary for him to file his return of income. In this case, although Mr. Robert Jonson is a non-resident sportsman, he has winnings from lotteries as well. Therefore, he cannot avail the benefit of exemption from filing of return of income as contained in section 115BBA. Hence, he has to file his return of income for A.Y.2025-26.