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NRI Taxation Under ITA 2025: Residential Status, DTAA, and Indian Income

Comprehensive guide to NRI taxation under ITA 2025. Covers residential status determination, taxability of Indian income, NRE/NRO account rules, DTAA benefits, and ITR filing.

TaxClue Team Tax & Compliance Expert
2 min read 0 views Updated May 24, 2026
Expert Reviewed High Complexity
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Non-Resident Indians (NRIs) have specific tax obligations in India under the Income Tax Act 2025. Tax liability depends primarily on residential status and the source of income. This guide covers how residential status is determined, what income is taxable, and how to avail DTAA benefits.

Residential Status — The Key Determinant

Under ITA 2025, an individual is a Resident in India if:

  • Present in India for 182 days or more during the Tax Year, OR
  • Present in India for 60 days or more in the Tax Year AND 365 days or more in the 4 preceding years

The 60-day rule is relaxed to 120 days for Indian citizens/PIOs with Indian income above Rs. 15 lakh. If an Indian citizen has total income > Rs. 15 lakh and is not taxable anywhere else, they are deemed resident in India (RNOR → Resident).

Categories of Residential Status

CategoryTaxable Income
Resident and Ordinarily Resident (ROR)Global income (India + foreign)
Resident but Not Ordinarily Resident (RNOR)India income + foreign income from India-controlled business
Non-Resident (NR)Only India-sourced income

What Income is Taxable for NRIs?

  • Salary for services rendered in India
  • Business income from India operations
  • Rental income from property in India
  • Capital gains on India assets (shares, property)
  • Interest income from NRO accounts
  • Dividends from Indian companies

Exempt for NRIs: Interest on NRE (Non-Resident External) accounts, interest on FCNR deposits.

NRE vs NRO vs FCNR Accounts

AccountCurrencyInterest Taxable?Repatriable?
NREINR (foreign source)No (exempt)Fully
NROINR (India income)Yes (TDS 30%)Up to $1M/year
FCNRForeign currencyNo (exempt)Fully

DTAA Benefits for NRIs

India has DTAAs with 90+ countries. NRIs can claim lower withholding tax rates on dividends, interest, and royalties under the applicable DTAA. To claim DTAA benefit:

  • Obtain Tax Residency Certificate (TRC) from the country of residence
  • File Form 10F with the Indian deductor/tax authority
  • Applicable beneficial rate will apply (e.g., US-India DTAA: 15% on dividends vs 20% default)

Capital Gains for NRIs

NRIs selling Indian property or shares must pay capital gains tax per ITA 2025 rates. TDS applies at source: 20% (LTCG) or 30% (STCG) before payment to NRI. NRI can apply to AO for lower TDS certificate (Form 13) if actual tax is lower.

ITR Filing by NRIs

NRIs must file ITR if Indian income exceeds Rs. 4 lakh (basic exemption) or if they have capital gains or want to claim refund of excess TDS. Applicable forms: ITR-2 (no business income) or ITR-3 (business income). Foreign bank accounts and assets must be disclosed in Schedule FA.

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Frequently Asked Questions
How is residential status determined for NRI under ITA 2025?
Based on days of physical presence in India: 182+ days = Resident. 60+ days in current year + 365+ days in 4 prior years = Resident (120-day rule for some Indian citizens with India income > Rs. 15L).
Is NRE account interest taxable in India?
No. Interest on NRE (Non-Resident External) accounts and FCNR deposits is fully exempt from tax in India.
What is TDS rate on NRI NRO account interest?
30% TDS is deducted on interest from NRO accounts. NRIs can claim DTAA benefits to reduce this rate by submitting TRC and Form 10F.
What is a Tax Residency Certificate (TRC)?
TRC is a certificate from the tax authority of the country of residence confirming the person is a tax resident there. Required to claim DTAA benefits in India.
Must NRIs file ITR in India?
Yes, if Indian income exceeds basic exemption (Rs. 4 lakh), or if they have capital gains from Indian assets, or want to claim TDS refund.
What is RNOR status?
Resident but Not Ordinarily Resident — a transitional status for returning NRIs who have been NR for 9 of the past 10 years. RNOR are taxed only on India income (not global income) for 2-3 years after return.

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