ABC Ltd., a company incorporated and tax resident in Country X, is a non-resident foreign company for Indian income-tax purposes. During the…

ABC Ltd., a company incorporated and tax resident in Country X, is a non-resident foreign company for Indian income-tax purposes. During the previous year 2025-26, it earned business income of ₹ 8,00,000 from a unit established at Delhi. It also received dividend income of ₹ 12,50,000 from UV Ltd., an Indian company listed on a recognized stock exchange. Further, on 1 October 2025, ABC Ltd. received 8% debentures of Geeta Ltd., an Indian company, having a face value of ₹ 20,00,000 as consideration for providing technical know-how. The interest on the debentures is payable annually on 31 March. ABC Ltd. also received dividend income of ₹ 5,50,000 on GDRs of Chetan Ltd., an Indian company, issued under a scheme of the Central Government against the initial issue of shares and purchased in foreign currency. In addition, it received royalty income of ₹ 10,00,000 from D Ltd., an Indian company, under an agreement approved by the Central Government. Assume there is no DTAA between India and Country X.