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Schedule IV to the Income-tax Act, 2025: income of foreign companies and other persons not included in total income (serial numbers 9 to 14)

Schedule IV (brought in by section 11) excludes the income in column B of the eligible persons in column C from total income if the conditions in column D are met. Many rows here...

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Last updated: October 2026Applies to: FY 2026-27 (AY 2027-28)Verified against: Government sources

Serial numbers 9 to 14 of the Table in Schedule IV to the Income-tax Act, 2025 deal with income of foreign companies and certain other persons that is not included in total income: lease rentals of cruise ships, income of the European Economic Community, income received in India in Indian currency, storage and sale of crude oil, and three serial numbers (13A, 13B and 13C) inserted by the Finance Act, 2026 on contract manufacturing, individuals visiting India for a notified scheme, and procuring data centre services. Serial numbers 1 to 8 are in our note on Schedule IV, serial numbers 1 to 8.

This explanation is as per the Income-tax Act, 2025 (30 of 2025) as amended by the Finance Act, 2026. Serial numbers 13A, 13B and 13C and Note 3 are printed as inserted by the Finance Act, 2026, with effect from 1 April 2026; Schedule IV is among those amended by section 124 of that Act. Under section 1(3) the Act came into force on the 1st April, 2026, save as otherwise provided. Later amendments, rules and notifications should be checked. For where the earlier Act's provisions on exempt income sit in the 2025 Act, see our mapping note on exemptions and the Schedules.

Serial number 9: cruise ship lease rentals

Serial numberIncome (column B)Eligible persons (column C)Conditions (column D)
9Income from lease rentals, by whatever name called, of cruise shipForeign company(a) Such income is received from a specified company which operates such ship or ships in India; (b) such foreign company and the specified company are subsidiaries of the same holding company; and (c) such income is received or accrues or arises in India for any relevant tax year beginning on or before the 1st April, 2029

Note 1 defines the terms for serial number 9:

  • "specified company" means any company, other than a domestic company, which operates cruise ships in India and opts to pay tax as per section 61(2) (Table: serial number 2), as printed;
  • "holding company", in relation to a foreign company or a specified company, means a company of which such companies are subsidiary companies; and
  • "subsidiary company" or "subsidiary", in relation to a holding company, means a company in which the holding company exercises or controls more than one-half of the total share capital, either at its own or together with one or more of its subsidiary companies.

All three conditions (a), (b) and (c) must be met.

Serial number 10: the European Economic Community

Serial numberIncome (column B)Eligible persons (column C)Conditions (column D)
10Any income derived in India by way of interest, dividends or capital gains from investments madeThe European Economic CommunitySuch investments are made out of its funds under such scheme as the Central Government may, by notification, specify

Note 2 says "European Economic Community" means the European Economic Community established by the Treaty of Rome of 25th March, 1957. The scheme notified is not in the text consulted.

Serial numbers 11 to 13: crude oil

Serial numberIncome (column B)Eligible persons (column C)Conditions (column D)
11Any income received in India in Indian currencyA foreign company(a) Such income is on account of sale of crude oil or any other goods or rendering of services, as may be notified by the Central Government, to any person in India; (b) receipt of such income in India by the foreign company is pursuant to an agreement or arrangement entered into by the Central Government or approved by the Central Government; (c) such foreign company and the agreement or arrangement are notified by the Central Government, having regard to the national interest; and (d) such foreign company is not engaged in any activity in India, other than activity resulting in such income
12Any income accruing or arising on account of storage of crude oil in a facility in India and sale of such crude oil to any person resident in IndiaA foreign company(a) Such storage and sale by the foreign company is pursuant to an agreement or arrangement entered into by the Central Government or approved by the Central Government; and (b) such foreign company and the agreement or arrangement are notified by the Central Government, having regard to the national interest
13Any income accruing or arising on account of sale of leftover stock of crude oil, if any, from the facility in India after the expiry of the agreement or arrangement referred to against serial number 12 or on termination of the said agreement or arrangementA foreign companySuch sale shall be as per the terms mentioned in the said agreement or arrangement, subject to such conditions as may be notified by the Central Government in this behalf

Serial number 11 has four conditions, all joined by "and"; serial number 12 has two. The foreign companies, agreements and arrangements that have been notified are not named in the text consulted.

Serial numbers 13A, 13B and 13C (inserted by the Finance Act, 2026)

These three serial numbers are printed in square brackets, with a footnote saying that they were inserted by the Finance Act, 2026, with effect from 1 April 2026.

Serial numberIncome (column B)Eligible persons (column C)Conditions (column D)
13AAny income arising on account of providing capital goods, equipment or tooling to a contract manufacturer, being a company resident in IndiaA foreign company, who is providing capital goods, equipment or tooling to the contract manufacturer for use in electronic manufacturing in India(a) Ownership of such capital goods, equipment or tooling remains with the foreign company; (b) such capital goods, equipment or tooling is under the control and direction of the contract manufacturer; (c) the contract manufacturer is located in a custom bonded area, that is, a warehouse referred to in section 65 of the Customs Act, 1962 (52 of 1962); (d) the contract manufacturer produces electronic goods on behalf of the foreign company for a consideration; (e) such exemption shall be available up to the tax year 2030-2031
13BAny income which accrues or arises outside India, and is not deemed to accrue or arise in IndiaAn individual, being a non-resident for a period of five consecutive tax years immediately preceding the tax year during which he visits India for the first time for rendering services in India in connection with any scheme as may be notified by the Central Government(a) Such individual, during the relevant tax year, renders any service in India in connection with any scheme as may be notified by the Central Government; (b) such exemption shall not be available beyond a period of five consecutive tax years commencing from the first tax year during which he visits India in connection with such scheme; and (c) such other conditions, as may be prescribed
13CAny income accruing or arising in India or deemed to accrue or arise in India by way of procuring data centre services from a specified data centreA foreign company(a) Such foreign company is notified by the Central Government in this behalf; (b) such foreign company does not own or operate any of the physical infrastructure or any resources of the specified data centre; (c) all sales by such foreign company to users located in India are made through a reseller entity being an Indian company; (d) such foreign company maintains and furnishes such information in such form and manner, as may be prescribed; and (e) such exemption shall be available up to tax year ending on the 31st March, 2047

The Customs Act, 1962 is another law; check it for the warehouse provision. For serial number 13B the scheme to be notified, and for the "other conditions" under (c), the detail is left to notification and to the Income-tax Rules, 2026; neither is in the text consulted.

Note 3 (inserted by the Finance Act, 2026): serial number 13C

  • "data centre" means a dedicated secure space within a building or centralised location where computing and networking equipment is concentrated for the purpose of collecting, storing, processing, distributing or allowing access to large amounts of data;
  • "data centre services" means the services provided by a data centre through the use of physical infrastructure, including land, buildings, mechanical electrical power equipment, cooling system, security and information technology infrastructure including servers, computers, storage systems, operating systems, security solutions, network and associated software platforms, networking and other equipment, human resource in India; and
  • "specified data centre" means a data centre which is (i) set up under an approved scheme and notified in this behalf by the Central Government in the Ministry of Electronics and Information Technology, and (ii) owned and operated by an Indian company.

Serial number 14

Serial numberIncome (column B)Conditions
14Any income falling under section 10(6A), (6B), (6BB), (15A), (15)(iiia), (15)(iiib), (15)(iiic) or (15)(iv)(a), (15)(iv)(b) or (15)(iv)(fa) of the Income-tax Act, 1961 (43 of 1961)Subject to the conditions as specified therein

At serial number 14 the Act itself names sections of the Income-tax Act, 1961; they are quoted as printed and nothing more is said about them. The row has no separate entries in columns C and D in the copy consulted; the closing words are the only condition.

A worked example (names and facts assumed)

Seacrest Holdings Limited, a foreign company, owns the tooling used by Eastbay Electronics Private Limited, an Indian company, to make electronic goods in a custom bonded area for Seacrest for a consideration. (All names and facts are assumed.)

  1. Serial number 13A applies to income arising from providing capital goods, equipment or tooling to a contract manufacturer that is a company resident in India, for use in electronic manufacturing in India.
  2. Conditions (a) to (d) are met if Seacrest retains ownership, the tooling is under Eastbay's control and direction, Eastbay is located in a warehouse referred to in section 65 of the Customs Act, 1962, and produces electronic goods on Seacrest's behalf for a consideration.
  3. Under condition (e), the exemption is available up to the tax year 2030-2031. For a tax year after 2030-2031, serial number 13A does not apply.

Need help with a foreign company's income in India?

These rows depend on notifications, agreements and, for the new serial numbers, prescribed conditions. Our non-resident tax filing team can read your facts against the rows and the notifications that apply.

Key takeaways

  • Serial number 9 covers cruise ship lease rentals received by a foreign company from a specified company under the same holding company, for a relevant tax year beginning on or before 1 April 2029.
  • Serial numbers 11 to 13 depend on agreements or arrangements and notifications of the Central Government.
  • Serial numbers 13A, 13B and 13C were inserted by the Finance Act, 2026, with effect from 1 April 2026.
  • Serial number 13A runs to the tax year 2030-2031; serial number 13C to the tax year ending 31 March 2047.
  • Serial number 13B gives a five-consecutive-tax-year window to an individual visiting India for a notified scheme.
  • Serial number 14 refers to sections of the Income-tax Act, 1961, as printed.

Read next

Disclaimer: Based on the Income-tax Act, 2025 (30 of 2025) as amended by the Finance Act, 2026, as consulted on 2 October 2026. It explains the words of the Act only; the Income-tax Rules, 2026, notifications, circulars, later amendments and the way the tax authorities and courts apply these provisions should be checked. This article is general information, not legal advice; check the official text before acting.

Quick recapKey facts & short answers

Key Facts About Schedule IV

  • Applies in: All states across India, under the relevant central law.
  • Mode: Mostly online via the official government portal.
  • Typical timeline: Ranges from a few days to a few weeks depending on the case.
  • Non-compliance: May attract penalties, interest or late fees.
  • Expert help: TaxClue completes the entire process end to end for you.

Which tax year limit applies to cruise ship lease rentals?

Condition (c) of serial number 9: a relevant tax year beginning on or before the 1st April, 2029.

Who qualifies under serial number 13A?

A foreign company providing capital goods, equipment or tooling to a contract manufacturer resident in India for electronic manufacturing in India, on the five conditions listed, available up to the tax year 2030-2031.

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Disclaimer: This article is for general informational purposes only and does not constitute professional tax, legal or financial advice. Laws, rates and due dates change and can vary by individual case — always verify with the relevant government source (e.g. mca.gov.in, incometax.gov.in) or consult a qualified professional before acting. TaxClue accepts no liability for decisions taken based on this content.

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Short, direct answers to the 7 questions readers ask most on this topic.

Condition (c) of serial number 9: a relevant tax year beginning on or before the 1st April, 2029.

A foreign company providing capital goods, equipment or tooling to a contract manufacturer resident in India for electronic manufacturing in India, on the five conditions listed, available up to the tax year 2030-2031.

Income accruing or arising outside India that is not deemed to accrue or arise in India, for an individual who was a non-resident for five consecutive tax years before first visiting India to render services under a notified scheme, for up to five consecutive tax years from the first such year.

That it is notified, does not own or operate the data centre's physical infrastructure or resources, makes all sales to users in India through an Indian company reseller, furnishes prescribed information, and claims within the period up to the tax year ending 31 March 2047.

Note 2 refers to the body established by the Treaty of Rome of 25th March, 1957.

No. They are notified by the Central Government; what has been notified is not in the text consulted.

The Act itself names those sections of the 1961 Act at the row, subject to the conditions specified therein; this note quotes them as printed.