Taxation - DT Ch 02: Residential Status - Test 2: answer key

Question 1 · 2 marks · Taxation - DT Ch 02: Residential Status · hard

Scenario. Mr. Rohan Malhotra, an Indian citizen, has been working in Dubai since 2021. He is not liable to tax in any other country by reason of his domicile or residence. During FY 2026-27, he visited India for 135 days. His total income from Indian sources (interest, rent, etc.) was ₹14,50,000. He earned ₹6,00,000 from foreign investments outside India. His cumulative stay in the four years preceding FY 2026-27 was 380 days. He did not maintain any business connection in India. Mr. Mohan Malhotra, his brother, also an Indian citizen, is working in Riyadh. He is not liable to tax in Saudi Arabia. During FY 2026-27, he stayed in India for 85 days. His total income from Indian sources was ₹16,50,000. His cumulative stay in the four years preceding FY 2026-27 was 300 days. Ms. Priya Sen, an Indian citizen, has been residing in London since 2018. She is not liable to tax in the UK. During FY 2026-27, she visited India for 125 days. Her total income from Indian sources was ₹17,00,000. Her cumulative stay in the four years preceding FY 2026-27 was 400 days.

What is the residential status of Mr. Rohan Malhotra for FY 2026-27 based on the facts of Case Scenario-I?

1. Non-resident under section 6(1) (correct answer)
2. Resident but not ordinarily resident under section 6(6)
3. Deemed resident under section 6(1A)
4. Resident and ordinarily resident under section 6(1)

Answer: A — Non-resident under section 6(1)

Explanation. Mr. Rohan stayed in India for 135 days. He is an Indian citizen visiting India, so the second basic condition of 60 days plus 365 days is not applied. The modified 120-day route applies only where total income other than income from foreign sources exceeds ₹15,00,000. His Indian income is ₹14,50,000, which does not exceed the threshold. Therefore, only the 182-day condition applies. Since 135 days is below 182 days, he is non-resident under section 6(1).

Where it goes wrong. Students may apply the 120-day route despite Indian income being below ₹15 lakh, or use the 365-day stay in the four preceding years.

Authority. Section 6(1) of the Income-tax Act, 1961

Question 2 · 2 marks · Taxation - DT Ch 02: Residential Status · hard

What is the residential status of Mr. Mohan Malhotra for FY 2026-27 based on the facts of Case Scenario-I?

1. Non-resident under section 6(1)
2. Deemed resident but not ordinarily resident under section 6(1A) (correct answer)
3. Resident but not ordinarily resident under section 6(6)
4. Resident and ordinarily resident under section 6(1)

Answer: B — Deemed resident but not ordinarily resident under section 6(1A)

Explanation. Mr. Mohan is an Indian citizen. He is not liable to tax in any other country. His total income from Indian sources is ₹16,50,000, which exceeds ₹15,00,000. He satisfies all conditions for deemed resident under section 6(1A). A deemed resident under section 6(1A) is always resident but not ordinarily resident. His stay of 85 days and four-year stay of 300 days do not affect this conclusion, as section 6(1A) overrides the basic conditions.

Where it goes wrong. Students may treat the 85-day stay as insufficient and wrongly classify him as non-resident, ignoring the deemed resident provision.

Authority. Section 6(1A) of the Income-tax Act, 1961

Question 3 · 2 marks · Taxation - DT Ch 02: Residential Status · medium

What is the residential status of Ms. Priya Sen for FY 2026-27 based on the facts of Case Scenario-I?

1. Non-resident under section 6(1)
2. Resident but not ordinarily resident under section 6(6)
3. Deemed resident but not ordinarily resident under section 6(1A) (correct answer)
4. Resident and ordinarily resident under section 6(1)

Answer: C — Deemed resident but not ordinarily resident under section 6(1A)

Explanation. Ms. Priya is an Indian citizen. She is not liable to tax in any other country. Her Indian income is ₹17,00,000, which exceeds ₹15,00,000. She is deemed resident under section 6(1A). A deemed resident is always resident but not ordinarily resident. Although she also satisfies the 120-day and 365-day conditions under section 6(1), the specific deemed resident provision applies. She cannot be treated as resident and ordinarily resident.

Where it goes wrong. Students may apply the 120-day route and conclude RNOR under section 6(6), missing the specific deemed resident provision.

Authority. Section 6(1A) of the Income-tax Act, 1961

Question 4 · 2 marks · Taxation - DT Ch 02: Residential Status · hard

If Ms. Priya Sen was liable to tax in the UK, what would be her residential status for FY 2026-27, assuming all other facts remain the same?

1. Non-resident under section 6(1)
2. Deemed resident under section 6(1A)
3. Resident and ordinarily resident under section 6(1)
4. Resident but not ordinarily resident under section 6(6) (correct answer)

Answer: D — Resident but not ordinarily resident under section 6(6)

Explanation. If Ms. Priya is liable to tax in the UK, section 6(1A) does not apply. She is an Indian citizen visiting India with Indian income of ₹17,00,000, which exceeds ₹15,00,000. She stayed 125 days, which is 120 days or more, and 400 days in the four preceding years, which is 365 days or more. She satisfies the modified basic condition and is resident. Since she stayed less than 182 days and the 120-day route applies, she is RNOR under section 6(6).

Where it goes wrong. Students may still apply section 6(1A) despite the liability to tax in the UK, or classify her as non-resident based on less than 182 days.

Authority. Section 6(1) of the Income-tax Act, 1961; Section 6(6) of the Income-tax Act, 1961

Question 5 · 2 marks · Taxation - DT Ch 02: Residential Status · hard

Scenario. Mr. Suresh Iyer, the Karta of Suresh Iyer HUF, manages the HUF's business operations. The control and management of the HUF's affairs are situated partly in India and partly in Dubai. The Karta was in India for 100 days in FY 2026-27. His cumulative stay in the seven years preceding FY 2026-27 was 750 days. He was non-resident in 8 out of the 10 tax years preceding FY 2026-27. Aryan Steels Ltd., an Indian company incorporated under the Companies Act 2013, has its registered office in Mumbai. However, all key management and commercial decisions are made by its Board of Directors in Singapore. The company's Place of Effective Management (POEM) is in Singapore. Zenith Global Inc., a foreign company, has its POEM in Mumbai, India, during FY 2026-27. Vikramaditya Tech Labs LLP, a partnership firm, has its control and management wholly in India. One of its partners is a non-resident. Nandini Real Estates Pvt Ltd., a company incorporated in India, has its entire management and control in Dubai.

What is the residential status of Suresh Iyer HUF for FY 2026-27 based on the facts of Case Scenario-II?

1. Resident and ordinarily resident under section 6(2) (correct answer)
2. Resident but not ordinarily resident under section 6(6)
3. Non-resident under section 6(2)
4. Deemed resident under section 6(1A)

Answer: A — Resident and ordinarily resident under section 6(2)

Explanation. The control and management of the HUF's affairs are partly in India and partly in Dubai, so the HUF is resident under section 6(2). For RNOR, the Karta must satisfy either the 9-out-of-10-years non-resident test or the 729-day test. The Karta was non-resident in 8 out of 10 years, so the first test is not met. His seven-year stay was 750 days, which exceeds 729 days. Both RNOR tests are not met, so the HUF is resident and ordinarily resident.

Where it goes wrong. Students may treat the Karta's non-resident status in 8 out of 10 years as sufficient for RNOR, ignoring the 9-out-of-10 requirement.

Authority. Section 6(2) of the Income-tax Act, 1961; Section 6(6) of the Income-tax Act, 1961

Question 6 · 2 marks · Taxation - DT Ch 02: Residential Status · medium

What is the residential status of Aryan Steels Ltd. for FY 2026-27 based on the facts of Case Scenario-II?

1. Non-resident under section 6(3)
2. Resident but not ordinarily resident under section 6(6)
3. Resident under section 6(3) (correct answer)
4. Deemed resident under section 6(1A)

Answer: C — Resident under section 6(3)

Explanation. Aryan Steels Ltd. is an Indian company incorporated under the Companies Act 2013. Under section 6(3), an Indian company is always resident in India, irrespective of its place of effective management. The fact that its key management and commercial decisions are made in Singapore does not affect its residential status. Therefore, Aryan Steels Ltd. is resident in India for FY 2026-27.

Where it goes wrong. Students may apply the POEM test to an Indian company and wrongly conclude that it is non-resident because POEM is in Singapore.

Authority. Section 6(3) of the Income-tax Act, 1961

Question 7 · 2 marks · Taxation - DT Ch 02: Residential Status · hard

What is the residential status of Zenith Global Inc. for FY 2026-27 based on the facts of Case Scenario-II?

1. Non-resident under section 6(3)
2. Resident but not ordinarily resident under section 6(6)
3. Deemed resident under section 6(1A)
4. Resident under section 6(3) (correct answer)

Answer: D — Resident under section 6(3)

Explanation. Zenith Global Inc. is a foreign company. Under section 6(3), a foreign company is resident in India if its place of effective management (POEM) is in India during the relevant tax year. Since its POEM is in Mumbai during FY 2026-27, it is resident in India. A company can only be resident or non-resident; it cannot be RNOR. Therefore, Zenith Global Inc. is resident in India for FY 2026-27.

Where it goes wrong. Students may classify the foreign company as non-resident because it is incorporated outside India, ignoring the POEM test.

Authority. Section 6(3) of the Income-tax Act, 1961

Question 8 · 2 marks · Taxation - DT Ch 02: Residential Status · medium

What is the residential status of Nandini Real Estates Pvt Ltd. for FY 2026-27 based on the facts of Case Scenario-II?

1. Non-resident under section 6(3)
2. Resident but not ordinarily resident under section 6(6)
3. Resident under section 6(3) (correct answer)
4. Deemed resident under section 6(1A)

Answer: C — Resident under section 6(3)

Explanation. Nandini Real Estates Pvt Ltd. is an Indian company incorporated in India. Under section 6(3), an Indian company is always resident in India regardless of where its management and control are situated. The fact that its entire management and control is in Dubai does not change its residential status. Therefore, the company is resident in India for FY 2026-27.

Where it goes wrong. Students may use the control and management test applicable to firms and HUFs, or the POEM test, and wrongly conclude non-resident status.

Authority. Section 6(3) of the Income-tax Act, 1961

Question 9 · 2 marks · Taxation - DT Ch 02: Residential Status · hard

Scenario. During Tax Year 2026-27, a registered taxpayer is evaluating statutory compliance, computation of taxable income, and eligible tax deductions in accordance with the provisions of the Income-tax Act, 2025 and applicable rules for the May 2027 examination.

Mr. Arjun Kapoor, an Indian citizen, is a resident of Canada. He is not liable to tax in Canada. During FY 2026-27, he visited India for 130 days. His total income from Indian sources is ₹14,80,000. His foreign income is ₹8,00,000. What is his residential status for FY 2026-27?

1. Non-resident under section 6(1) (correct answer)
2. Resident but not ordinarily resident under section 6(6)
3. Deemed resident under section 6(1A)
4. Resident and ordinarily resident under section 6(1)

Answer: A — Non-resident under section 6(1)

Explanation. Mr. Arjun is an Indian citizen visiting India. His Indian income is ₹14,80,000, which does not exceed ₹15,00,000. Therefore, the deemed resident provision under section 6(1A) does not apply. The modified 120-day route under section 6(1) also requires income exceeding ₹15,00,000. Thus, only the 182-day condition applies. He stayed 130 days, which is below 182 days. He is non-resident.

Where it goes wrong. Students may ignore the ₹15 lakh threshold for section 6(1A) and the 120-day route, or wrongly apply the 60-day basic condition.

Authority. Section 6(1) of the Income-tax Act, 1961; Section 6(1A) of the Income-tax Act, 1961

Question 10 · 2 marks · Taxation - DT Ch 02: Residential Status · medium

Scenario. During Tax Year 2026-27, a registered taxpayer is evaluating statutory compliance, computation of taxable income, and eligible tax deductions in accordance with the provisions of the Income-tax Act, 2025 and applicable rules for the May 2027 examination.

Ms. Kavita Rao, an Indian citizen, left India for the first time on 1st August 2026 for employment in Germany. She stayed in India from 1st April 2026 to 1st August 2026. Her Indian income is ₹20,00,000 and she is not liable to tax in Germany. What is her residential status for FY 2026-27?

1. Non-resident under section 6(1)
2. Deemed resident but not ordinarily resident under section 6(1A) (correct answer)
3. Resident but not ordinarily resident under section 6(6)
4. Resident and ordinarily resident under section 6(1)

Answer: B — Deemed resident but not ordinarily resident under section 6(1A)

Explanation. Ms. Kavita is an Indian citizen. She is not liable to tax in any other country. Her Indian income is ₹20,00,000, which exceeds ₹15,00,000. She satisfies the conditions for deemed resident under section 6(1A). A deemed resident is always resident but not ordinarily resident. Her stay in India from 1 April to 1 August 2026 is 123 days, but this is not relevant once section 6(1A) applies.

Where it goes wrong. Students may count the days of stay and apply the 182-day or 60-day basic condition, or wrongly classify her as non-resident.

Authority. Section 6(1A) of the Income-tax Act, 1961

Question 11 · 2 marks · Taxation - DT Ch 02: Residential Status · hard

Scenario. During Tax Year 2026-27, a registered taxpayer is evaluating statutory compliance, computation of taxable income, and eligible tax deductions in accordance with the provisions of the Income-tax Act, 2025 and applicable rules for the May 2027 examination.

Mr. Rakesh Sharma, a non-resident, is a partner in a firm. The firm's control and management is wholly in India. What is the residential status of the firm for FY 2026-27?

1. Non-resident under section 6(2)
2. Resident but not ordinarily resident under section 6(6)
3. Resident under section 6(2) (correct answer)
4. Deemed resident under section 6(1A)

Answer: C — Resident under section 6(2)

Explanation. For a partnership firm, the residential status depends on the control and management of its affairs. If the control and management is situated wholly or partly in India, the firm is resident. Since the firm's control and management is wholly in India, it is resident under section 6(2). The residential status of the partner is not relevant for determining the firm's status. A firm cannot be RNOR or deemed resident.

Where it goes wrong. Students may consider the non-resident status of the partner and wrongly conclude that the firm is non-resident.

Authority. Section 6(2) of the Income-tax Act, 1961

Question 12 · 2 marks · Taxation - DT Ch 02: Residential Status · hard

Scenario. During Tax Year 2026-27, a registered taxpayer is evaluating statutory compliance, computation of taxable income, and eligible tax deductions in accordance with the provisions of the Income-tax Act, 2025 and applicable rules for the May 2027 examination.

Mr. Rohan Malhotra, an Indian citizen, is not liable to tax in any other country. His Indian income is ₹16,00,000. He stayed in India for 100 days during FY 2026-27. What is his residential status for FY 2026-27?

1. Non-resident under section 6(1)
2. Resident but not ordinarily resident under section 6(6)
3. Resident and ordinarily resident under section 6(1)
4. Deemed resident but not ordinarily resident under section 6(1A) (correct answer)

Answer: D — Deemed resident but not ordinarily resident under section 6(1A)

Explanation. Mr. Rohan is an Indian citizen. He is not liable to tax in any other country. His Indian income is ₹16,00,000, which exceeds ₹15,00,000. He satisfies the conditions for deemed resident under section 6(1A). A deemed resident is always resident but not ordinarily resident. His stay of 100 days does not affect this status because section 6(1A) overrides the basic conditions of section 6(1).

Where it goes wrong. Students may classify him as non-resident because he stayed only 100 days, ignoring the deemed resident provision.

Authority. Section 6(1A) of the Income-tax Act, 1961

Question 13 · 2 marks · Taxation - DT Ch 02: Residential Status · hard

Scenario. During Tax Year 2026-27, a registered taxpayer is evaluating statutory compliance, computation of taxable income, and eligible tax deductions in accordance with the provisions of the Income-tax Act, 2025 and applicable rules for the May 2027 examination.

A HUF's control and management is partly in India and partly in Dubai. The Karta was non-resident in 9 out of the 10 tax years preceding FY 2026-27. What is the residential status of the HUF for FY 2026-27?

1. Resident but not ordinarily resident under section 6(6) (correct answer)
2. Resident and ordinarily resident under section 6(2)
3. Non-resident under section 6(2)
4. Deemed resident under section 6(1A)

Answer: A — Resident but not ordinarily resident under section 6(6)

Explanation. Since the control and management of the HUF is partly in India, the HUF is resident under section 6(2). For determining whether it is ROR or RNOR, the Karta's status is considered. The Karta was non-resident in 9 out of 10 preceding years, which satisfies one of the conditions for RNOR under section 6(6). Therefore, the HUF is resident but not ordinarily resident for FY 2026-27.

Where it goes wrong. Students may overlook the Karta's 9-out-of-10 non-resident status or wrongly classify the HUF as non-resident.

Authority. Section 6(2) of the Income-tax Act, 1961; Section 6(6) of the Income-tax Act, 1961

Question 14 · 2 marks · Taxation - DT Ch 02: Residential Status · medium

Scenario. During Tax Year 2026-27, a registered taxpayer is evaluating statutory compliance, computation of taxable income, and eligible tax deductions in accordance with the provisions of the Income-tax Act, 2025 and applicable rules for the May 2027 examination.

A partnership firm's control and management is wholly outside India during FY 2026-27. What is the residential status of the firm for FY 2026-27?

1. Resident under section 6(2)
2. Non-resident under section 6(2) (correct answer)
3. Resident but not ordinarily resident under section 6(6)
4. Deemed resident under section 6(1A)

Answer: B — Non-resident under section 6(2)

Explanation. For a partnership firm, the residential status depends on the control and management of its affairs. If the control and management is situated wholly outside India, the firm is non-resident. Since the entire control and management is outside India, the firm is non-resident under section 6(2). A firm cannot be RNOR or deemed resident; those categories apply only to individuals and HUFs.

Where it goes wrong. Students may apply the RNOR concept to the firm or wrongly treat it as resident because it may have Indian partners.

Authority. Section 6(2) of the Income-tax Act, 1961

Question 15 · 2 marks · Taxation - DT Ch 02: Residential Status · hard

Scenario. During Tax Year 2026-27, a registered taxpayer is evaluating statutory compliance, computation of taxable income, and eligible tax deductions in accordance with the provisions of the Income-tax Act, 2025 and applicable rules for the May 2027 examination.

Mr. Vikram, an Indian citizen, is not liable to tax in any other country. His Indian income is ₹15,00,000. He stayed in India for 150 days during FY 2026-27. What is his residential status for FY 2026-27?

1. Resident but not ordinarily resident under section 6(6)
2. Deemed resident under section 6(1A)
3. Non-resident under section 6(1) (correct answer)
4. Resident and ordinarily resident under section 6(1)

Answer: C — Non-resident under section 6(1)

Explanation. Mr. Vikram is an Indian citizen visiting India. His Indian income is ₹15,00,000, which does not exceed ₹15,00,000. Therefore, the deemed resident provision under section 6(1A) does not apply. The modified 120-day route under section 6(1) also requires income exceeding ₹15,00,000. Thus, only the 182-day condition applies. He stayed 150 days, which is below 182 days. He is non-resident.

Where it goes wrong. Students may treat income equal to ₹15 lakh as exceeding the threshold and wrongly apply section 6(1A) or the 120-day route.

Authority. Section 6(1) of the Income-tax Act, 1961; Section 6(1A) of the Income-tax Act, 1961

Question 16 · 2 marks · Taxation - DT Ch 02: Residential Status · medium

Scenario. During Tax Year 2026-27, a registered taxpayer is evaluating statutory compliance, computation of taxable income, and eligible tax deductions in accordance with the provisions of the Income-tax Act, 2025 and applicable rules for the May 2027 examination.

What does the term 'Place of Effective Management' (POEM) mean for determining the residential status of a company under section 6(3) of the Income-tax Act, 1961?

1. Place where the registered office is situated
2. Place where the board meetings are usually held
3. Place where the majority of employees are located
4. Place where key management and commercial decisions are made (correct answer)

Answer: D — Place where key management and commercial decisions are made

Explanation. Place of Effective Management (POEM) means a place where key management and commercial decisions that are necessary for the conduct of the business of the company as a whole are, in substance, made. It is not necessarily the registered office, the place of board meetings, or the location of the majority of employees. POEM is used to determine the residential status of a foreign company under section 6(3).

Where it goes wrong. Students may confuse POEM with the registered office or the place where board meetings are held, which are not the statutory test.

Authority. Section 6(3) of the Income-tax Act, 1961

Question 17 · 2 marks · Taxation - DT Ch 02: Residential Status · hard

Scenario. During Tax Year 2026-27, a registered taxpayer is evaluating statutory compliance, computation of taxable income, and eligible tax deductions in accordance with the provisions of the Income-tax Act, 2025 and applicable rules for the May 2027 examination.

An Indian citizen, not liable to tax in any other country, has Indian income of ₹16,00,000 and foreign income of ₹5,00,000. He stayed in India for 100 days during FY 2026-27. He is:

1. Deemed resident but not ordinarily resident under section 6(1A) (correct answer)
2. Resident but not ordinarily resident under section 6(6)
3. Non-resident under section 6(1)
4. Resident and ordinarily resident under section 6(1)

Answer: A — Deemed resident but not ordinarily resident under section 6(1A)

Explanation. The individual is an Indian citizen. He is not liable to tax in any other country. His Indian income is ₹16,00,000, which exceeds ₹15,00,000. He satisfies all conditions for deemed resident under section 6(1A). A deemed resident is always resident but not ordinarily resident. His stay of 100 days and foreign income of ₹5,00,000 do not change this status.

Where it goes wrong. Students may focus on the 100-day stay and classify him as non-resident, ignoring the deemed resident provision.

Authority. Section 6(1A) of the Income-tax Act, 1961

Question 18 · 2 marks · Taxation - DT Ch 02: Residential Status · hard

Scenario. During Tax Year 2026-27, a registered taxpayer is evaluating statutory compliance, computation of taxable income, and eligible tax deductions in accordance with the provisions of the Income-tax Act, 2025 and applicable rules for the May 2027 examination.

A HUF is resident. The Karta was non-resident in 9 out of the 10 tax years preceding FY 2026-27. What is the residential status of the HUF for FY 2026-27?

1. Resident and ordinarily resident
2. Non-resident
3. Deemed resident
4. Resident but not ordinarily resident (correct answer)

Answer: D — Resident but not ordinarily resident

Explanation. For a resident HUF, the status of ROR or RNOR depends on the Karta's position. Under section 6(6), a HUF is RNOR if the Karta is non-resident in 9 out of the 10 tax years preceding the relevant year, or if the Karta stayed in India for 729 days or less in the seven preceding years. The Karta was non-resident in 9 out of 10 years, so the HUF is RNOR.

Where it goes wrong. Students may treat the HUF as ROR or non-resident without applying the specific Karta-based tests for RNOR.

Authority. Section 6(6) of the Income-tax Act, 1961

Question 19 · 2 marks · Taxation - DT Ch 02: Residential Status · medium

Scenario. During Tax Year 2026-27, a registered taxpayer is evaluating statutory compliance, computation of taxable income, and eligible tax deductions in accordance with the provisions of the Income-tax Act, 2025 and applicable rules for the May 2027 examination.

Does an Indian company need to satisfy the Place of Effective Management (POEM) test to be considered resident in India for FY 2026-27?

1. Yes, POEM must be in India
2. No, it is always resident if incorporated in India (correct answer)
3. Yes, POEM must be in India for at least 182 days
4. No, it is resident only if POEM is in India

Answer: B — No, it is always resident if incorporated in India

Explanation. Under section 6(3), a company is resident in India if it is an Indian company or if its POEM is in India. For an Indian company, the place of incorporation is sufficient; POEM is not required to be in India. Therefore, an Indian company is always resident in India, irrespective of its POEM.

Where it goes wrong. Students may think POEM is a mandatory condition for all companies, including Indian companies, and wrongly answer that POEM must be in India.

Authority. Section 6(3) of the Income-tax Act, 1961

Question 20 · 2 marks · Taxation - DT Ch 02: Residential Status · medium

Scenario. During Tax Year 2026-27, a registered taxpayer is evaluating statutory compliance, computation of taxable income, and eligible tax deductions in accordance with the provisions of the Income-tax Act, 2025 and applicable rules for the May 2027 examination.

Section 6(1A) of the Income-tax Act, 1961, which provides for deemed resident status, applies to:

1. All individuals
2. Indian citizens and persons of Indian origin
3. Only Indian citizens (correct answer)
4. Only persons of Indian origin

Answer: C — Only Indian citizens

Explanation. Section 6(1A) applies only to an individual who is a citizen of India. It does not apply to a person of Indian origin who is not an Indian citizen. The provision covers an Indian citizen whose total income other than income from foreign sources exceeds ₹15,00,000 and who is not liable to tax in any other country. Such a person is deemed resident but not ordinarily resident.

Where it goes wrong. Students may extend the deemed resident provision to persons of Indian origin, but the statute specifically requires Indian citizenship.

Authority. Section 6(1A) of the Income-tax Act, 1961