Mr. Vikram, a foreign citizen and a Person of Indian Origin (PIO), resides in Country Z. He operates an international management consultancy firm.…

6. (i) An individual would be resident in India if he satisfies any one of the basic conditions provided under section 6(1): (a) Stay in India during the previous year is 182 days or more, OR (b) Stay in India during the previous year is 60 days or more, AND 365 days or more during the 4 immediately preceding previous years. As per Explanation 1(b) to section 6(1), if an individual is an Indian citizen or a Person of Indian Origin (PIO) comes on a visit to India in a previous year, he would be considered as resident only if he stayed in India for 182 days or more during that previous year. However, if such an Indian citizen or PIO has "total income other than income from foreign sources" exceeding ₹ 15,00,000 during the relevant previous year, then he would also be resident in India, if he stays for at least 120 days during the previous year and for 365 days or more during the 4 years immediately preceding the previous year. His total income other than income from foreign sources would be as follows: Particulars Amount (₹) Amount (₹) I. Income from House Property A. Residential House Property in New Delhi Gross Annual Value (GAV) 3,50,000 Less: Municipal Taxes (Nil, since taxes paid by the tenant are not allowed) - Net Annual Value (NAV) 3,50,000 Less: Statutory Deduction @ 30% of NAV (30% of ₹ 3,50,000) (1,05,000) 2,45,000 B. Commercial Building in Country Z [Not includible since income from commercial building is sourced entirely from outside India] 2,45,000 II. Profits and Gains of Business or Profession Professional fees for conducting corporate training sessions in India. 1,75,000 Income from management consultancy setup in Country Z (Includible since it is derived from a profession set up and registered in India). 8,50,000 10,25,000 III. Income from Other Sources Interest earned on Fixed Deposits with the State Bank of India 2,20,000 Net income from agricultural operations in Sri Lanka (accrues or arise outside India) Nil 2,20,000 Total Income other than income from foreign sources 14,90,000 Since Mr. Vikram's total income other than income from foreign sources do not exceed ₹ 15 lakhs and he stayed in India during the P.Y. 2025-26 only for 132 days which is less than 182 days, he is a non-resident in India for the P.Y. 2025-26. (ii) As per section 5(2), a non-resident is chargeable to tax in India in respect of income received or deemed to be received in India or income which accrues or arise or deemed to accrues or arise to him in India. Accordingly, his gross total income would be as follows: Particulars Amount (₹) Total Income other than income from foreign source as computed above 14,90,000 Less: Income derived from management consultancy setup in Country Z (Not Taxable since accrues or arises outside India) 8,50,000 Gross Total Income 6,40,000