Q1. Residential Status of Mr.

Ram

Facts:

 Indian citizen
 First departure from India on 22.09.2024 for employment in Germany
 For AY 2025–26, the “relevant previous year” is FY 2024–25.

Analysis:
Under Section 6(1) of the IT Act, an individual is resident if either of these tests is met:

1. Being in India for 182 days or more in the relevant previous year, or
2. Being in India for 60 days or more during the relevant previous year and at least 365
days during the 4 preceding years.

Since Mr. Ram left on 22.09.2024, his stay from 1 April 2024 up to 21 September 2024 is
approximately 174 days (well above the 60-day minimum) and – assuming he was present in
India in all the previous years – his four‐year total clearly exceeds 365 days.
Thus, he meets the second condition. Moreover, since until now he has been resident in India,
there is no basis to qualify as “resident but not ordinarily resident.”

Answer Q1:
Mr. Ram will be resident and ordinarily resident for AY 2025–26.

Q2. Residential Status of Mr. Dey

Facts:

 Residing in the US since 1990; used to visit India for 30 days per year
 Returned permanently to India on 1.04.2023
 For AY 2025–26, the relevant previous year is FY 2024–25.

Analysis:
For FY 2024–25, Mr. Dey, having returned permanently from 1.04.2023, is present in India
throughout the year (i.e. about 365 days). Although under the standard day-count rule he is
“resident,” the additional criteria for classifying a resident as “resident but not ordinarily
resident” (RNOR) come into play. One key RNOR condition is that the individual has been
non-resident in 9 out of the 10 preceding years. (Alternatively, a “low Indian income” test
applies, but that is not the case here.)
Since Mr. Dey had been non-resident for many years until his permanent return, his status
will be resident but not ordinarily resident.

Answer Q2:
For AY 2025–26, Mr. Dey will be resident but not ordinarily resident (RNOR).

Q3. Gross Total Income Computation for Mr. Ramesh and Mr. Suresh
Both have opted out of the default provisions under Section 115BAC(1A) (i.e. they are taxed
under the new regime) but for computing the gross total income the steps are common.
(Deductions available under Chapter VI-A are not considered here.)

Given details:

Sr.
Particulars Ramesh Suresh
No.
Interest on Canada Development Bonds (only 50% 35,000 → 40,000 →
1
taxable) 17,500 20,000
2 Dividend from British company, received in London 28,000 20,000
Profits from a business in Nagpur (managed from
3 1,00,000 1,40,000
London)
Short-term capital gain on sale of shares (received in
4 60,000 90,000
India)
5 Income from a business in Chennai 80,000 70,000
Fees for technical services rendered in India,
6 1,00,000 –
received in Canada
7 Interest on savings bank deposit in UCO Bank, Delhi 7,000 12,000
Agricultural income from land in Andhra Pradesh
8 55,000 45,000
(Exempt)
9 Rent received in respect of house property at Bhopal 1,00,000 60,000

Computation (excluding agricultural income):

For Mr. Ramesh:

1. Canada Bonds: 17,500

2. Dividend (British company): 28,000
3. Nagpur business profits: 1,00,000
4. STCG on shares: 60,000
5. Chennai business income: 80,000
6. Technical services fees: 1,00,000
7. Savings bank interest: 7,000
8. Rent income: 1,00,000

Total = 17,500 + 28,000 + 1,00,000 + 60,000 + 80,000 + 1,00,000 + 7,000 + 1,00,000

= 4,92,500

For Mr. Suresh:

1. Canada Bonds: 20,000

2. Dividend (British company): 20,000
3. Nagpur business profits: 1,40,000
4. STCG on shares: 90,000
5. Chennai business income: 70,000
6. Technical services fees: Nil
7. Savings bank interest: 12,000
8. Rent income: 60,000

Total = 20,000 + 20,000 + 1,40,000 + 90,000 + 70,000 + 12,000 + 60,000

= 4,12,000
Answer Q3:

 Mr. Ramesh’s Gross Total Income: ₹4,92,500

 Mr. Suresh’s Gross Total Income: ₹4,12,000

Q4. Tax Computation with Additional Incomes

The “final income” now is that computed in Q3 plus the following items (which were not
originally included):

 Long-term capital gain under Section 112A: Rs.3,00,000 each

 Agriculture income of Rs.1,00,000 each is exempt (hence not added for tax purposes).

Revised Total Income:

 For Mr. Ramesh: 4,92,500 + 3,00,000 = ₹7,92,500

 For Mr. Suresh: 4,12,000 + 3,00,000 = ₹7,12,000

Tax Rate Assumptions:

For illustration, assume the following slab structure (old regime for Ramesh and new regime
for Suresh):

 Up to ₹2,50,000: NIL
 ₹2,50,001 – ₹5,00,000: 5%
 ₹5,00,001 – ₹10,00,000: 20%
(Additional cess at 4% is applied on tax computed.)

Computation for Mr. Ramesh (Old Regime):

1. Income above ₹2,50,000 = 7,92,500 – 2,50,000 = 5,42,500

2. For next ₹2,50,000 at 5%: Tax = 2,50,000 × 5% = 12,500
3. Remaining = 5,42,500 – 2,50,000 = 2,92,500 at 20%: Tax = 2,92,500 × 20% = 58,500
4. Total Tax = 12,500 + 58,500 = 71,000
5. Add cess @4% = 71,000 × 0.04 = 2,840
6. Total Tax Liability ≈ ₹73,840

Computation for Mr. Suresh (New Regime):

Under the new regime, the slab rates (for an individual below 60) are:

 Up to ₹2,50,000: NIL
 ₹2,50,000–₹5,00,000: 5%
 ₹5,00,000–₹7,50,000: 10%
(Cess at 4% applies as well.)

1. For income up to ₹2,50,000: Nil

2. Next ₹2,50,000 (₹2.5L to ₹5L): 2,50,000 × 5% = 12,500
3. Remaining = 7,12,000 – 5,00,000 = 2,12,000 at 10% = 21,200
4. Total Tax = 12,500 + 21,200 = 33,700
5. Add cess @4% = 33,700 × 0.04 ≈ 1,348
6. Total Tax Liability ≈ ₹35,048
Answer Q4:

 Mr. Ramesh (Old Regime): Total tax ≈ ₹73,840

 Mr. Suresh (New Regime): Total tax ≈ ₹35,048

Q5. Deemed Income – Interest, Royalty and Fees for Technical Services

Statement:
“Income deemed to accrue or arise in India to a non-resident by way of interest, royalty and
fees for technical services is to be taxed irrespective of territorial nexus.”

Analysis:
Under Section 9 of the IT Act, the source rule is applied. For non-residents, income of the
nature of interest, royalty, and fees for technical services is deemed to accrue or arise in India
if it is received or receivable from an Indian source—even if there is no direct physical or
territorial nexus. This principle has been repeatedly confirmed by judicial pronouncements
and is the basis for withholding tax provisions in treaties and domestic law.

Answer Q5:
The statement is correct because, under Indian tax law, such incomes are taxed on the basis
of their source in India irrespective of whether the economic activity or the payment has a
physical connection to the country.

Q6. Taxability of Selected Transactions

Examine each transaction from the viewpoint of the recipient:

(i) Salary by Central Government to Mr. John

 Facts: Indian citizen; salary = ₹7,00,000; services rendered outside India; taxpayer
opts for tax computed under Section 115BAC (new regime).
 Analysis:
The crucial factor is the place where services are rendered. Since Mr. John renders his
services entirely outside India, under the “source” rules the salary does not accrue or
arise in India, even though paid by the government.
 Conclusion:
Not taxable in India.

(ii) Interest on Borrowed Moneys by a Non-resident

 Facts: A non-resident borrows ₹5,00,000 from outside India to fund a business in

Mumbai.
 Analysis:
Interest income on funds employed for business in India is deemed to accrue in India
—even if the money is borrowed from a foreign source. Consequently, the lender (the
recipient of the interest) will find such income taxable in India, as per the “source”
provisions.
 Conclusion:
Taxable in India (in the hands of the lender receiving the interest).
(iii) Post Office Savings Bank Interest received by Mr. Ram

 Facts: Mr. Ram (resident, age 46) receives ₹19,000 as interest, and he has opted to
shift out of the default regime under Section 115BAC(1A).
 Analysis:
Under the new regime, exemptions available under sections such as 80TTA are not
available; thus the entire interest becomes taxable.
 Conclusion:
Fully taxable (entire amount of ₹19,000 is included in taxable income).

(iv) Royalty Paid by a Resident to a Non-resident

 Facts: Royalty relates to business carried on outside India.

 Analysis:
Royalty income is taxable in India only if it accrues or arises in India. Since the
underlying business is carried on outside India, the royalty does not have an Indian
source.
 Conclusion:
Not taxable in India.

(v) Legal Charges Paid to a UK Lawyer

 Facts: Legal charges of ₹5,00,000 paid in Delhi for representation in a Delhi High
Court case.
 Analysis:
Since the legal services are rendered in India (i.e. at the Delhi High Court), the
income accruing to the UK lawyer is deemed to have arisen in India, notwithstanding
the lawyer’s residence.
 Conclusion:
Taxable in India.

Q7. Taxation Issues Involving Dr. Sharma and His Consultancy Firm

(a) Residential Status of Dr. Sharma Individually

Facts:

 Indian citizen; worked abroad; stayed in India for only 90 days in the relevant
previous year; global income exceeds ₹20 lakhs.

Analysis:
For individuals, residency is determined by either a stay of 182 days or, alternatively, 60 days
in the relevant year plus 365 days in the preceding four years. Here, 90 days in the relevant
year meets the 60-day threshold; however, if Dr. Sharma has been non-resident for 9 out of
the preceding 10 years (likely given his working abroad), he would be classified as resident
but not ordinarily resident (RNOR).

Answer (a):
Dr. Sharma is likely resident but not ordinarily resident.

(b) Residential Status of the Consultancy Firm and Taxability under Section 9
Facts:

 Registered office in Mumbai, but all key management and strategic decisions are
made in London.

Analysis:
Under the “place of effective management” rule, the residential status of a company depends
on where its key management and commercial decisions are taken. Here, since such decisions
are made in London, the firm is deemed to be managed from abroad and hence is treated as
non-resident for tax purposes.

 Indian government project income: Even though the firm is non-resident, income
that accrues from business operations in India (such as the Indian government project)
is taxable in India under Section 9.
 Foreign consultancy fees: These are generated from business activities carried out
outside India and are not taxed in India.

Answer (b):
The firm will be treated as non-resident (by virtue of its “place of effective management”).
Its income from the Indian government project is taxable in India under Section 9, while its
foreign consultancy fees are not.

(c) Comparison of Taxability if Dr. Sharma Were a Non-resident Versus RNOR

Analysis:

 Non-resident: Tax liability in India is limited exclusively to income that accrues or

arises in India. In Dr. Sharma’s case, this would typically include the salary received
for the Indian government assignment and any interest on Indian bank deposits. The
foreign consultancy fees (earned outside India) would not be taxed in India.
 Resident but not ordinarily resident (RNOR): In this status, like for non-residents,
only income arising in India is taxable (i.e. the foreign income remains outside the
scope of Indian taxation).
 Key Difference: In contrast, if Dr. Sharma were classified as a “resident and
ordinarily resident,” his global income would be taxable in India. Since under both
non-resident and RNOR statuses foreign income is excluded, the salary (if attributable
to Indian service) and interest income are taxable in India but not his foreign
consultancy fees.

Answer (c):
Whether as a non-resident or as RNOR, only Indian-sourced income (the salary from the
Indian government project and interest on the fixed deposit) is taxable in India. If he were
“resident and ordinarily resident,” his entire global income – including the foreign
consultancy fees – would be subject to tax in India.

Q8. Comparative Total Income Computation for Ms. Kapoor

Income Components:

1. Short-term capital gains from sale of shares (Indian company, received in France):
₹25,000
 2. Dividend from Japanese company (received in Japan): ₹12,000
3. Rental income from a property in London:
- Gross = ₹90,000; Standard deduction at 30% = 0.30 × 90,000 = ₹27,000;
- Net rental income = ₹90,000 – ₹27,000 = ₹63,000
4. Dividend from Indian company: ₹8,000
5. Agricultural income from Punjab land: ₹30,000 (exempt)

(a) Total Taxable Income under Different Statuses:

(i) Resident and Ordinarily Resident (ROR)

 Global income is taxable.

 Taxable Income = ₹25,000 + ₹12,000 + ₹63,000 + ₹8,000 = ₹108,000
 (Agricultural income remains exempt.)

(ii) Resident but Not Ordinarily Resident (RNOR)

 Only income that accrues or arises in India is taxable.

• Short-term capital gains on shares of an Indian company are generally taxable
even if received abroad.
• Dividend from the Indian company is taxable.
• The dividend from the Japanese company and rental income (property in London)
are foreign‐sourced and not taxable.
 Taxable Income = ₹25,000 + ₹8,000 = ₹33,000

(iii) Non-resident

 Similarly, only Indian-sourced income is taxable.

 Taxable Income = ₹25,000 + ₹8,000 = ₹33,000

Answer Q8:

 (i) ROR: ₹1,08,000

 (ii) RNOR: ₹33,000
 (iii) Non-resident: ₹33,000

Q9. Multi-Year Stay Analysis for Mr. Verma

Facts:

 Relevant previous year: 150 days in India

 Preceding four years: 95, 110, 85, and 100 days = 390 days in total
(Note: One year included a 25-day overseas assignment which is not counted;
however, the provided totals already reflect exclusion.)
 Total income (excluding foreign-source income) in relevant year: ₹18 lakhs

(a) Determining Residential Status

 Even though Mr. Verma does not meet the 182-day threshold in the relevant year, he
meets the second test (more than 60 days in the current year and at least 365 days in
the preceding four years).
  Thus, he is resident.

(b) Classification as “Resident but Not Ordinarily Resident”

 One condition for RNOR is that the individual must have been non-resident in 9 out
of the 10 preceding years.
 With 390 days over four years (and a total of 680 days over 7 years as given), there is
no evidence that he meets the RNOR conditions.
 Thus, he is Resident and Ordinarily Resident (ROR).

(c) Income Threshold Interaction

 The “income threshold” (the “low-income” test, commonly for determining RNOR) is
that an individual whose total income (excluding specified incomes) is below ₹5
lakhs may be classified as RNOR.
 Mr. Verma’s income of ₹18 lakhs is well above this threshold, and he does not satisfy
the “non-resident in 9 out of 10 years” condition.
 Thus, the high income and his recent stay pattern ensure that he is classified as
ROR.

Answer Q9:
(a) Resident
(b) He cannot be classified as RNOR; he is ROR.
(c) The income threshold (₹5 lakhs) is used as one of the conditions to qualify for RNOR;
since his income is ₹18 lakhs, it reinforces that his global income is taxable – confirming his
status as ROR.

Q10. Residential Status of Mr. Kumar

Facts:

 Relevant previous year: 150 days in India (≥ 60 days, but < 182 days)
 Preceding four years: Total of 400 days (≥ 365 days)

Analysis:
Since Mr. Kumar meets the second test (more than 60 days in the relevant year and at least
365 days in the preceding four years), he is classified as resident. There is no indication of
conditions that would lead to RNOR.

Answer Q10:
Mr. Kumar is resident and ordinarily resident.

Q11. Residential Status of Mr. Singh – Seafarer

Facts:

 Employed as a crew member on a foreign-bound ship.

 Joined the ship on 5th June and signed off on 20th November in the relevant previous
year.
Step 1: Exclusion of Voyage Days

 The period from 5th June to 20th November is considered an overseas voyage and is
excluded.

Calculation:

 5th June to 30th June: 26 days (inclusive count: 30 – 5 + 1)

 July: 31 days
 August: 31 days
 September: 30 days
 October: 31 days
 November: 20 days
 Total excluded = 26 + 31 + 31 + 30 + 31 + 20 = 169 days

Step 2: Determining Effective Stay

 Mr. Singh’s “stay in India” is computed after excluding these 169 days.
 Provided that his remaining days in India (outside the voyage period) do not total 182
(or satisfy the alternate test), he will be treated as non-resident.

Answer Q11:

 Excluded days: 169

 Likely Outcome: After excluding the voyage period, Mr. Singh does not meet the
required number of days; hence, he would be classified as non-resident.

Q12. Residential Status of a HUF Operating from Overseas

Facts:

 The HUF operates its business entirely from overseas.

 Some family members reside in India.

Analysis:
For any entity, including an HUF, the determining factor is where the control and
management of its affairs is exercised. Even if some family members live in India, if the
HUF’s key decisions and overall management are conducted from overseas, the HUF is
considered non-resident for tax purposes. Only income accruing or arising in India (for
example, from an immovable property located in India) would be taxable.

Answer Q12:
The HUF’s residential status depends on the location of its control and management. In this
case, as the effective management is overseas, the HUF is non-resident.

Q13. Residential Status of Ms. Sharma

Facts:
  Indian citizen working abroad
 Visited India for 110 days in the relevant previous year
 Total income (excluding foreign income) = ₹20 lakhs

Analysis:
Since she is present for more than 60 days but less than 182 days in the relevant year, she
qualifies under the “60-day and 365-day” rule provided her preceding four years’ presence
meets the criterion. However, if she was non-resident in 9 out of the 10 preceding years (a
typical scenario for professionals working abroad), she would be classified as resident but
not ordinarily resident (RNOR). The income threshold (low income below ₹5 lakhs) is not
met here, but the key RNOR condition of “non-residence in 9 out of 10 years” may be
satisfied.

Answer Q13:
Assuming she has been non-resident in the majority of the preceding years, Ms. Sharma will
be classified as resident but not ordinarily resident.

Q14. Total Income and Tax Computation for an Individual with Mixed
Income

Incomes Given:

1. Short-term capital gains on share sale: ₹1,50,000

2. Dividend from a foreign company: ₹10,000
3. Rental income from a London property:
– Gross = ₹75,00,000;
– Standard deduction @30% = 0.30 × 75,00,000 = ₹22,50,000
– Net Rental Income = 75,00,000 – 22,50,000 = ₹52,50,000
4. Dividend from an Indian company: ₹6,00,000
5. Agricultural income from land in Gujarat: ₹25,00,000 (exempt under normal
circumstances)

(A) For a Resident and Ordinarily Resident (ROR):

Global income is taxable (except the exempt agricultural income).

Taxable Income =
= (STCG) ₹1,50,000 + (Foreign dividend) ₹10,000 + (Net Rental Income) ₹52,50,000 +
(Indian dividend) ₹6,00,000
= ₹1,50,000 + ₹10,000 + ₹52,50,000 + ₹6,00,000
= ₹60,10,000

Tax Calculation (assuming old regime slabs):

 Up to ₹2,50,000: NIL
 Next ₹2,50,000 at 5% = ₹12,500
 Balance = ₹60,10,000 – ₹5,00,000 = ₹55,10,000 at 20% = ₹11,02,000
 Basic tax ≈ ₹12,500 + ₹11,02,000 = ₹11,14,500
 Add cess @4%: 0.04 × 11,14,500 ≈ ₹44,580
 Total tax ≈ ₹11,59,080
(Note: The exact computation may vary with applicable surcharges and cess; the figures
provided are indicative.)

(B) For a Resident but Not Ordinarily Resident (RNOR):

Only income accruing or arising in India is taxable.

 Taxable Indian-source income:

• STCG on share sale (₹1,50,000) – (shares of an Indian company are taxable even
if received abroad)
• Dividend from Indian company (₹6,00,000)
 The foreign dividend and rental income from London are not taxable for RNOR as
they are foreign-sourced.

Total taxable income (RNOR) = ₹1,50,000 + ₹6,00,000 = ₹7,50,000

Tax Calculation (using the same slab structure as before):

 Up to ₹2,50,000: NIL
 Next ₹2,50,000 at 5% = ₹12,500
 Remaining ₹2,50,000 at 20% = ₹50,000
 Basic tax = ₹12,500 + ₹50,000 = ₹62,500
 Add cess @4% = ₹2,500
 Total tax ≈ ₹65,000

Answer Q14:

 Resident and Ordinarily Resident: Total taxable income ≈ ₹60,10,000 with tax of
approximately ₹11,59,080 (indicative calculation).
 Resident but Not Ordinarily Resident: Total taxable income = ₹7,50,000 with total
tax ≈ ₹65,000.

Q15. Residential Status of an Indian Company via POEM

Facts:

 Incorporated in India with a registered office in Mumbai

 Key strategic decisions are made at the head office in Singapore

Analysis:
Under the “place of effective management” (POEM) rule, the residential status of a company
is determined by the location where key management and strategic decisions are taken. In this
case, despite its Indian incorporation and registered office, since the effective management is
in Singapore, the company is treated as non-resident for Indian tax purposes.

Answer Q15:
The company will be non-resident.

Q16. Treatment of Salary Income for an Indian Citizen (Non-resident)

Scenario:
An Indian citizen who is non-resident renders services entirely outside India and later
returns.

Analysis:

 While non-resident:
• Salary income for services rendered outside India is not taxed in India, as tax
liability for non-residents is limited to income that accrues or arises in India.
 On return (if the period of stay in the relevant previous year increases):
• If, on return, the individual qualifies as resident (or resident and ordinarily
resident), then global income – including salary earned abroad after return – becomes
taxable in India.
 Determining factors:
• The location where the services are actually rendered (source of the income).
• The period of physical presence in India during the relevant previous year.
• The timing of the return in relation to the period of assessment.

Answer Q16:
For an Indian citizen who is a non-resident, salary income for services rendered entirely
outside India is not taxable in India. However, once the individual returns and if his period
of stay in the relevant previous year meets the residency criteria, then any salary attributed to
services rendered in India (or received in India) becomes taxable. The determining conditions
are the location where the services are rendered and the number of days of physical presence
in India.

MCQs

 Mr. A, an Indian citizen working abroad, visited India for 65 days with 365 days in the
preceding four years and income below ₹15 lakhs. Answer: c) Non-resident Explanation:
For an Indian citizen working abroad, the basic condition is 182 days or more in India during
the previous year, OR 60 days or more during the year plus 365 days during the preceding
four years. While Mr. A meets the second part (365 days in preceding four years), his stay of
65 days would normally qualify him as resident. However, the limit of 60 days is extended to
182 days for Indian citizens working abroad. Therefore, with only 65 days in India, he falls
below the extended threshold and is a non-resident.
 Indian citizen crew member with voyage period and 180 days effective stay in India.
Answer: c) Non-resident Explanation: For crew members of an Indian ship, the period of
voyage doesn't count toward their presence in India. With an effective stay of 180 days
(excluding voyage), this person falls below the 182-day threshold required to be classified as
a resident. Since both basic conditions for residency aren't met, the crew member is a non-
resident.
 HUF with affairs controlled partly in India, Karta resident for 3 out of 10 years with 750
days over past 7 years. Answer: b) Resident but not ordinarily resident Explanation: A
HUF is resident if control and management of its affairs is wholly or partly situated in India.
Since control is partly in India, it's resident. For "ordinarily resident" status, the Karta must be
taxed as a resident in at least 7 out of 10 preceding years. Here, the Karta has been resident
only for 3 years out of 10, making the HUF "resident but not ordinarily resident."
 Company with registered office in India but key management decisions from overseas.
Answer: c) Non-resident Explanation: Under the "place of effective management" (POEM)
concept, a company is resident in India if it is either incorporated in India OR its place of
effective management is in India. While this company is incorporated in India (registered
office), the question specifies that all key management decisions are made from overseas
headquarters. This means the POEM is outside India, making the company a non-resident.
 Non-resident seafarer with salary credited to NRE account for services outside India.
Answer: b) It is not taxable in India Explanation: For a non-resident, only income that
accrues, arises, or is received in India is taxable. In this case, the salary is for services
rendered outside India and credited to an NRE account. NRE accounts have special status,
and foreign income credited to these accounts is not considered as income received in India
for tax purposes. Therefore, this income is not taxable in India.
 Criterion NOT for classification as resident under section 6(1). Answer: d) Counting
both the day of arrival and departure as days in India Explanation: The criteria for
residency include spending 182+ days in India during the previous year or spending 60+ days
in the relevant year with 365+ days in the preceding four years. Being an Indian citizen may
affect these thresholds but isn't itself a criterion. The method of counting days (including
arrival but excluding departure) is a procedural matter, not a criterion listed in section 6(1).
 Residential status of a Hindu Undivided Family (HUF) is determined by: Answer: c) The
control and management of its affairs Explanation: A HUF is deemed resident in India if
the control and management of its affairs is wholly or partly situated in India during the
previous year. The other factors listed may influence but don't directly determine residential
status under tax law.
 Type of income subject to tax in India for a non-resident: Answer: c) Income that
accrues or arises in India during the previous year Explanation: For non-residents, only
income that accrues, arises, or is received in India is taxable. Income from agricultural land in
India would qualify under this rule. Global income earned outside India is not taxable for
non-residents, nor is foreign dividend income unless received in India.
 Correct statement regarding deemed resident status under section 6(1A): Answer: c) It
applies only to Indian citizens with specified levels of foreign income Explanation:
Section 6(1A) creates a "deemed resident" category for Indian citizens who are not liable to
tax in any other country by reason of domicile or residence, and whose total income (other
than foreign sources) exceeds ₹15 lakhs during the previous year. It doesn't require a
minimum stay of 182 days, doesn't apply to all individuals regardless of citizenship, and isn't
automatically granted based solely on income level.

 "Place of effective management" for determining company's residential status: Answer: c)

The location where key management and strategic decisions are made Explanation: The
"place of effective management" refers to the location where key management and
commercial decisions necessary for conducting the business are made. It's about substantive
decision-making rather than day-to-day operations, registered office location, or shareholder
residence.