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“non-resident”

Chapter I - PreliminarySection 2 - DefinitionsSection 2(30) / Section 6 / ITR Forms3,736 judgments

The decision most relied on for non-resident is GE India Technology Centre Pvt. Ltd. v. CIT (327 ITR 456), cited in 663 judgments on BharatTax.

Leading authorities on non-resident

GE India Technology Centre Pvt. Ltd. v. CIT
327 ITR 456 · 2010 · Supreme Court
663
citing judgments

Tax must be deducted at source from payments made to a non-resident under Section 195 only if such payment is chargeable to tax in India. The Assessing Officer bears the onus to establish that the payments made are indeed chargeable to tax under the Income Tax Act.

CIT v. Samsung Electronics Ltd.
345 ITR 494 · 2012 · High Court
461
citing judgments

Payments by Indian residents to non-resident foreign software suppliers for software are considered royalty, constituting income deemed to accrue in India under section 9(1)(v), thereby requiring tax deduction at source under section 195.

Ishikawajima Harima Heavy Industries Ltd. v. DIT
288 ITR 408 · 2007 · Supreme Court
394
citing judgments

Income from offshore supply of goods and services is not taxable in India if the entire transaction, including transfer of ownership and payments, occurs outside India.

CIT v. De Beers India Minerals (P.) Ltd.
346 ITR 467 · 2012 · High Court
371
citing judgments

For fees for technical or consultancy services to 'make available' technical knowledge or know-how under a DTAA, the service must transmit such knowledge, allowing the recipient to derive an enduring benefit and utilize it independently in the future.

CIT v. Toshoku Ltd.
125 ITR 525 · 1980 · Supreme Court
270
citing judgments

A non-resident commission agent is not chargeable to tax in India on commission income if no business operations are carried out in India. Consequently, no TDS is required under Section 195 on such payments.

DIT v. Infrasoft Ltd.
39 Taxmann.com 88 · 2013 · High Court
269
citing judgments

Payments for the use of copyrighted software, without the transfer of any rights in the underlying copyright itself, do not constitute 'royalty' under the Income-tax Act or tax treaties. Such payments are often treated as business income, taxable only if a permanent establishment exists.

Transmission Corporation of Andhra Pradesh v. CIT
239 ITR 587 · 1999 · Supreme Court
243
citing judgments

The Supreme Court lays down principles for deducting tax at source (TDS) under Section 195 on payments to non-residents, including aspects of income deemed taxable in India and the application of Double Taxation Avoidance Agreements (DTAAs) under Section 90.

ONGC v. CIT
376 ITR 306 · 2015 · Supreme Court
241
citing judgments

Income derived by a non-resident for services related to mineral oil operations, falling under the presumptive taxation regime of Section 44BB, cannot simultaneously be treated as fees for technical services under Section 9(1)(vii). The specific presumptive provisions override the general FTS definition, particularly when DTAA applies.

Judgments citing non-resident

Income Tax Officer, Ward 29(1), New Delhi vs. Sneh Sharma, New Delhi

ITA 2136/DEL/2025[2012-13]Status: DisposedITAT Delhi24 Sept 2025AY 2012-13

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

For Appellant: Shri Anil Bajaj, CAFor Respondent: Shri Manish Gupta, Sr. DR
Section 124(3)Section 143(1)Section 144CSection 144C(1)Section 144C(15)Section 147Section 195

with regard to the appeals for 2015-16 and 2017-18, the ld. AR has pointed out that the assessee is a non-resident individual residing in the United Kingdom and this fact is not disputed by the Revenue. The assessee’s return ... were filed declaring her status as non-resident. Later, the return was processed u/s 143(1) of the Act vide intimation dated 16.03.2022. The AO was fully conscious of this aspect and, accordingly in the show cause notice as well as the impugned assessment order specifically notes that

ITO, Ward- 44(2), New Delhi vs. Threepence Craft, New Delhi

ITA 5995/DEL/2019[2011-12]Status: DisposedITAT Delhi24 Sept 2025AY 2011-12

Bench: Shri Challa Nagendra Prasad & Shri M Balaganesh

Section 143(3)Section 195(2)Section 263

section 9 of the I.T. Act are not applicable as the assessee has not paid any amount during the year to the non-resident. 10. Ld. Counsel further referring to page 85 of the Paper Book submitted that this is a letter filed in the course of assessment proceedings before ... frame fresh assessment after examining all aspects in respect of genuineness of purchases and export sales apart from holding that trade discount allowed to non-resident (treating the said non- resident as an agent of the assessee) and assessing the trade discount allowed is nothing but commission paid on export

Threepence Craft, New Delhi vs. ITO, Ward- 44(2), New Delhi

ITA 5410/DEL/2019[2011-12]Status: DisposedITAT Delhi24 Sept 2025AY 2011-12

Bench: Shri Challa Nagendra Prasad & Shri M Balaganesh

Section 143(3)Section 195(2)Section 263Section 40

section 9 of the I.T. Act are not applicable as the assessee has not paid any amount during the year to the non-resident. 10. Ld. Counsel further referring to page 85 of the Paper Book submitted that this is a letter filed in the course of assessment proceedings before ... frame fresh assessment after examining all aspects in respect of genuineness of purchases and export sales apart from holding that trade discount allowed to non-resident (treating the said non- resident as an agent of the assessee) and assessing the trade discount allowed is nothing but commission paid on export

Threepence Craft, New Delhi vs. CIT- IX, New Delhi

ITA 2234/DEL/2015[2011-12]Status: DisposedITAT Delhi24 Sept 2025AY 2011-12

Bench: Shri Challa Nagendra Prasad & Shri M Balaganesh

Section 143(3)Section 195(2)Section 263

section 9 of the I.T. Act are not applicable as the assessee has not paid any amount during the year to the non-resident. 10. Ld. Counsel further referring to page 85 of the Paper Book submitted that this is a letter filed in the course of assessment proceedings before ... frame fresh assessment after examining all aspects in respect of genuineness of purchases and export sales apart from holding that trade discount allowed to non-resident (treating the said non- resident as an agent of the assessee) and assessing the trade discount allowed is nothing but commission paid on export

Cochin International Airport Limited, Cochin vs. DCIT Corporate Circle 1(1), Cochin

In the result, all the appeals filed by the assessee are allowed

ITA 724/COCH/2023[2009-10]Status: DisposedITAT Cochin23 Sept 2025AY 2009-10

Bench: Shri Inturi Rama Rao & Shri Soundararajan K.

For Appellant: Shri Gopi K, CAFor Respondent: Shri Omanakuttan, Snr. AR
Section 195Section 201Section 9(1)(i)Section 9(1)(vii)

appeal before the Tribunal and the Tribunal also vide its order dated 12/01/2016 in ITA Nos. 311 to 315/Coch/2014 had held that the non-residents are not having any business connection in India. The Tribunal also questioned the finding of the Ld.CIT(A) that the two entities have ... whether the said payments are eligible for exemption as per the DTAA. Finally, the AO arrived the conclusion that the non-residents do not have any business connection and PE in India. The AO further held that the fees payable to the said two non-residents are taxable

Cochin International Airport Limited, Cochin vs. DCIT Corporate Circle 1(1), Cochin

In the result, all the appeals filed by the assessee are allowed

ITA 723/COCH/2023[2008-09]Status: DisposedITAT Cochin23 Sept 2025AY 2008-09

Bench: Shri Inturi Rama Rao & Shri Soundararajan K.

For Appellant: Shri Gopi K, CAFor Respondent: Shri Omanakuttan, Snr. AR
Section 195Section 201Section 9(1)(i)Section 9(1)(vii)

appeal before the Tribunal and the Tribunal also vide its order dated 12/01/2016 in ITA Nos. 311 to 315/Coch/2014 had held that the non-residents are not having any business connection in India. The Tribunal also questioned the finding of the Ld.CIT(A) that the two entities have ... whether the said payments are eligible for exemption as per the DTAA. Finally, the AO arrived the conclusion that the non-residents do not have any business connection and PE in India. The AO further held that the fees payable to the said two non-residents are taxable

Cochin International Airport Limited, Cochin vs. DCIT Corporate Circle 1(1), Cochin

ITA 722/COCH/2023[2007-08]Status: DisposedITAT Cochin23 Sept 2025AY 2007-08

Bench: Shri Inturi Rama Rao & Shri Soundararajan K.

For Appellant: Shri Gopi K, САFor Respondent: Shri Omanakuttan, Snr. AR
Section 195Section 201Section 9(1)(i)Section 9(1)(vii)

appeal before the Tribunal and the Tribunal also vide its order dated 12/01/2016 in ITA Nos. 311 to 315/Coch/2014 had held that the non-residents are not having any business connection in India. The Tribunal also questioned the finding of the Ld.CIT(A) that the two entities have ... whether the said payments are eligible for exemption as per the DTAA. Finally, the AO arrived the conclusion that the non-residents do not have any business connection and PE in India. The AO further held that the fees payable to the said two non-residents are taxable

Cochin International Airport Limited, Cochin vs. DCIT Corporate Circle 1(1), Cochin

In the result, all the appeals filed by the assessee are allowed

ITA 721/COCH/2023[2006-07]Status: DisposedITAT Cochin23 Sept 2025AY 2006-07

Bench: Shri Inturi Rama Rao & Shri Soundararajan K.

For Appellant: Shri Gopi K, CAFor Respondent: Shri Omanakuttan, Snr. AR
Section 195Section 201Section 9(1)(i)Section 9(1)(vii)

appeal before the Tribunal and the Tribunal also vide its order dated 12/01/2016 in ITA Nos. 311 to 315/Coch/2014 had held that the non-residents are not having any business connection in India. The Tribunal also questioned the finding of the Ld.CIT(A) that the two entities have ... whether the said payments are eligible for exemption as per the DTAA. Finally, the AO arrived the conclusion that the non-residents do not have any business connection and PE in India. The AO further held that the fees payable to the said two non-residents are taxable

Cochin International Airport Limited, Cochin vs. DCIT Corporate Circle 1(1), Cochin

ITA 720/COCH/2023[2005-06]Status: DisposedITAT Cochin23 Sept 2025AY 2005-06

Bench: Shri Inturi Rama Rao & Shri Soundararajan K.

For Appellant: Shri Gopi K, CAFor Respondent: Shri Omanakuttan, Snr. AR
Section 195Section 201Section 9(1)(i)Section 9(1)(vii)

appeal before the Tribunal and the Tribunal also vide its order dated 12/01/2016 in ITA Nos. 311 to 315/Coch/2014 had held that the non-residents are not having any business connection in India. The Tribunal also questioned the finding of the Ld.CIT(A) that the two entities have ... whether the said payments are eligible for exemption as per the DTAA. Finally, the AO arrived the conclusion that the non-residents do not have any business connection and PE in India. The AO further held that the fees payable to the said two non-residents are taxable

Faisal Badruddin Shitware, Mumbai vs. Income Tax Officer (Int Tax Ward)-4(2)(1), Mumbai

In the result, appeal of the assessee is allowed

ITA 4081/MUM/2025[2016-17]Status: DisposedITAT Mumbai23 Sept 2025AY 2016-17

Bench: Smt. Beena Pillai & Smt. Renu Jauhrifaisal Badruddin Ao Ward 4(2)(1), Kautilya Shitware Bhavan, Bandra Kurla 307, 1A, Delux Nagar Vs. Complex, Mumbai 400051 Building, Jeevan Baug, Post Room No. 209, 2Nd Floor, Office Road, Mumbra, Thane Aayakar Bhavan, M.K. Road, 400612 Mumbai 400020 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Bvops1660L (Appellant) (Respondent) निर्ााररती की ओर से / Assessee By: Shri. Nishit Gandhi /Revenue By: Shri Krishna Kumar Sr. Dr Date Of Hearing 06.08.2025 Date Of Pronouncement 23.09.2025 आदेश/O R D E R Per Renu Jauhri [A.M]: This Appeal Is Filed By The Assessee Against The Order Of The Ao Ward 4(2)(1), Mumbai Dated 17.12.2024 Passed As Per The Directions Of The Dispute Resolution Panel (Drp) U/S. 144C(5) Of The Income Tax Act, 1961 [Hereinafter Referred To As "Act"] For Assessment Year [A.Y.] 2016-17. 2. The Assessee Has Raised The Following Grounds Of Appeal:

For Appellant: Shri. Nishit GandhiFor Respondent: Shri Krishna Kumar SR. DR
Section 115BSection 144CSection 144C(5)Section 147Section 151ASection 153Section 5Section 69

entire re-assessment from initiation to completion is completely contrary to the extant law and deserves to be quashed; ii. The Petitioner, a Non-resident assessee, has no taxable income in India and therefore no income escaping assessment during the relevant year. iii. To the admission ... that: i. Section 69 is not at all applicable in the present case in as much as the Assessee (the Appellant herein) is a non-resident and therefore even to invoke section 69, the first requisite is to satisfy the scope of income as defined

Prakash Raman, Vadodara vs. Income-Tax Officer, International Taxation Ward 2 (1), Chennai

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 1115/CHNY/2025[2019-20]Status: DisposedITAT Chennai22 Sept 2025AY 2019-20

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri Jagadishआयकरअपील सं./ Ita No.1115/2025 (धििाारणवर्ा / Assessment Year: 2019-20) Prakash Raman, Vs. Income Tax Officer, Pent House No.602, 6Th Floor, (International Taxation), Pincode@55, Vasant Vihar Road, Ward-2(1), Tp-1, Opp. To Darshanam Chennai. Splendora, Bhayli, Vadodara, Gujarat-391 410. [Pan:Aappp0380F] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Appellant By : Mr.Abdul Kadir Jawadwala, C.A (Virtual). प्रत्यर्थी की ओर से /Respondent By : Mrs. R.Anitha, Addl.Cit सुनवाई की तारीख/Date Of Hearing : 20.08.2025 घोषणा की तारीख /Date Of Pronouncement : 22.09.2025

For Appellant: Mr.Abdul Kadir Jawadwala, C.A (Virtual)For Respondent: Mrs. R.Anitha, Addl.CIT
Section 234BSection 5Section 90

prevailing on the subject, the CIT(A) / AO has erred in not appreciating the fact that the Appellant is admittedly a non-resident for the year under consideration and consequently as per the provisions of section 5 read with sections 9 and 15 of the Act only salary income ... assessee. 16. We have heard the rival submissions and perused the record and case laws cited. The status of the assessee here is a Non-Resident Indian. The computation of total income of a Non-Resident has been stated in Section 5(2) of the Act and reproduced below

Birla Carbon India Private Limited, Mumbai vs. The Principal Commissioner of Income Tax, Mumbai - 5, Mumbai

In the result, the appeal is allowed as indicated above

ITA 3768/MUM/2025[2018-19]Status: DisposedITAT Mumbai22 Sept 2025AY 2018-19

Bench: Shri Saktijit Dey & Shri Narendra Kumar Billaiyabirla Carbon India Private Limited The Principal Commissioner Of Ground Floor, Aditya Birla Centre, Income Tax Room No. 515, 5Th Floor, Aaykar S. K. Ahire Marg, Worli, Vs. Mumbai-400 030 Bhavan, M. K. Road, Mumbai-400 020 Pan/Gir No. Aascs 9916 L (Appellant) : (Respondent) Appellant By : Shri Madhur Agarwal Respondent By : Shri Satyaprakash R. Singh Date Of Hearing : 16.09.2025 Date Of Pronouncement : 22.09.2025 O R D E R Per Saktijit Dey: In The Present Appeal, The Assessee Has Called Into Question The Validity Of The Order Dated 25.03.2025, Passed U/S. 263 Of The Income Tax Act, 1961 (‘The Act’ For Short) By Learned Principal Commissioner Of Income Tax (‘Ld.Pcit’ For Short), Pertaining To The Assessment Year (A.Y.) 2018-19. 2. Thought Multiple Grounds Have Been Raised In The Memorandum Of Appeal, However, The Assessee Has Raised A Pertinent Preliminary Issue, Challenging The Competence & Jurisdiction Of Ld. Pcit To Invoke Powers U/S. 263 Of The Act To Revise An Assessment Order Passed U/S. 144C(13) Of The Act, In Pursuance To The Directions Of Learned Dispute Resolution Panel (Ld. Drp).

For Appellant: Shri Madhur AgarwalFor Respondent: Shri Satyaprakash R. Singh
Section 143(3)Section 144C(1)Section 144C(13)Section 263Section 92C

arises as a consequence of the order of the Transfer Pricing Officer passed under sub- section (3) of section 92CA; and (ii) any non-resident not being a company, or any foreign company.] 18. A reading of the said section brings to the fore following:- 8 Birla Carbon India Private

Isat Africa Limited Fzc, United Arab Emirates vs. Deputy Commissioner of Income Tax, Mumbai

In the result, the final assessment order passed by AO is set aside and the appeal of the assessee is accordingly allowed in above terms

ITA 832/MUM/2024[2018-19]Status: DisposedITAT Mumbai22 Sept 2025AY 2018-19

Bench: Ms. Padmavathy S & Shri Raj Kumar Chauhanisat Africa Limited Fzc Vs. The Deputy Commissioner Office No. 5 Pre-Fab, C Phase Ii, Of Income Tax Fujairah Free Zone Fujairah, Dubai, International Tax Circle- United Arab Emirates, Dubai - 2(2)(2) 999999 Mumbai, Maharashtra. Pan – Aagci8661Q (Appellant) (Respondent)

Section 143(3)Section 144C(5)Section 148Section 148ASection 195Section 201Section 9(1)Section 9(1)(vi)

Africa Limited FZC 2. The brief facts as culled out from the order of authorities below are that theassesseei.e.ISAT Africa Ltd FZC is a Non-Resident entity, tax resident in UAE. As per the official website, it is involved in the business of providing integrated communications services to its customers ... available insight portal of Income-tax Department, it is noticed that M/s. BT Global Communication (BTGC) India Pvt. Ltd. had made various remittances to non-resident entities, including ISAT Africa Ltd FZC, on which it had not deducted any TDS. It was found that the transactions for which remittances were

Siemens Aktiengesellschaft, Mumbai vs. Asstt. CIT (International Taxation)-Circle-4(2)(1), Mumbai

In the result, grounds No

ITA 2259/MUM/2022[2018-19]Status: DisposedITAT Mumbai22 Sept 2025AY 2018-19

Bench: Smt. Beena Pillai () & Smt. Renu Jauhri ()

Section 253(1)(d)Section 92C(3)

receipt basis as per double taxation avoidance agreement between India and Germany and has observed and held as under: “78.The assessee is a non-resident Company, incorporated in Germany, having taxable income in India. With regard to FTS and royalty is has shown income on receipt basis ... Madras High Court in the case of Standard Triumph Motors Ltd. (119 ITR 573) which has held that in case of non-resident, Section 5(2)(a) of the Income tax Act i.e., will have no application andtaxabilitywillbedeterminedonlyunderSection5(2)(b) of the Income Tax Act, i.e., by accrual. Subsequently

Siemens Aktiengesellschaft, Mumbai vs. Asstt. CIT (International Taxation)-Circle-4(2)(1), Mumbai

In the result, grounds No

ITA 1615/MUM/2022[2017-18]Status: DisposedITAT Mumbai22 Sept 2025AY 2017-18

Bench: Smt. Beena Pillai () & Smt. Renu Jauhri ()

Section 253(1)(d)Section 92C(3)

receipt basis as per double taxation avoidance agreement between India and Germany and has observed and held as under: “78.The assessee is a non-resident Company, incorporated in Germany, having taxable income in India. With regard to FTS and royalty is has shown income on receipt basis ... Madras High Court in the case of Standard Triumph Motors Ltd. (119 ITR 573) which has held that in case of non-resident, Section 5(2)(a) of the Income tax Act i.e., will have no application andtaxabilitywillbedeterminedonlyunderSection5(2)(b) of the Income Tax Act, i.e., by accrual. Subsequently

Forcepoint International Technology Limited, Noida vs. ACIT, Circle Int. Taxation 1(3)(1), New Delhi

In the result, appeal of assessee in ITA No

ITA 976/DEL/2023[2020-21]Status: DisposedITAT Delhi22 Sept 2025AY 2020-21

Bench: Shri Anubhav Sharma & Shri Naveen Chandra

For Appellant: Shri Anil Bhalla, CAFor Respondent: Shri Vijay B. Basanta CIT- DR
Section 139(1)Section 9(1)(vii)

facts and in law by ignoring the fact that what is paid by way of consideration by the distributor in India to the foreign, non-resident manufacturer or supplier, is the price of the computer programm as goods, either in a medium which stores the software or in a medium ... Vs.The ACIT 126-132 & PB 154-158).We thus find that the distributor in India pays by way of consideration to the foreign, non-resident manufacturer or supplier, the price of the computer software programme as supply of goods via internet as SaaS on the cloud, which is then further

Azb and Partner, Mumbai vs. PCIT-8, Mumbai

ITA 4105/MUM/2025[2020-21]Status: DisposedITAT Mumbai19 Sept 2025AY 2020-21

Bench: Shri Vikram Singh Yadav & Shri Anikesh Banerjee

For Appellant: Shri Yogesh Thar & Shri VinayakFor Respondent: Shri Rajesh Kumar Yadav (CIT-DR)
Section 143(3)Section 144BSection 195Section 263

Form 15CA filed under Rule 37BB of the Income tax Rule,1962, being the prescribed form for furnishing information regarding payments to non-residents (other than companies) or to foreign companies. The designated remarks column also contained the specific reasons for non-deduction of TDS. It was further submitted that

Appdynamics International Limited, United Kingdom vs. Assistant Commissioner of Income-Tax, (International Taxation), Circle-1(1)(1), Delhi

In the result, appeal of the assessee in ITA No

ITA 3743/DEL/2023[AY 2021-22]Status: DisposedITAT Delhi19 Sept 2025

Bench: Shri Challa Nagendram Prasad & Shri Naveen Chandra

For Appellant: Shri Nageswar Rao, AdvFor Respondent: Shri Siddharth Bhim Singh Meena, CIT-DR

majority of sales coming from subscriptions. Post the acquisition of AppDynamics group, AppD International became the distributor of Cisco products. AppD International is a non-resident foreign company incorporated in the United Kingdom, engaged in the sale of off-the-shelf software. AppD International does not have any presence

Meena Swarup, New Delhi vs. DCIT Circle-3(1)(2), New Delhi

In the result, appeal of the assessee is allowed

ITA 2050/DEL/2019[2014-15]Status: DisposedITAT Delhi19 Sept 2025AY 2014-15

Bench: Shri Sudhir Kumar & Shri Manish Agarwal[Assessment Year : 2014-15] Mrs. Meena Swarup, Vs Dcit, 397, Mandakini Enclave, Circle-3(1)(2), New Delhi-110019. Intl. Tax., Pan-Amrps5792E New Delhi. Appellant Respondent Appellant By Shri R.S.Ahuja, Ca & Shri P.S.Sodhi, Adv. Respondent By Shri Dheeraj Kumar Jain, Sr.Dr Date Of Hearing 01.07.2025 Date Of Pronouncement 19.09.2025 Order Per Manish Agarwal, Am :

Section 10(38)Section 143(2)Section 143(3)Section 250Section 68

pertaining to Assessment Year 2014-15. 2. Brief facts of the case are that assessee is an individual and is non-resident and return of income was filed on 31.07.2014 declaring total income of INR 47,320/- with ITO, Ward-22(4), Delhi in terms of the e-filing acknowledgement ... from ITO ward 30(2) Delhi to the DCIT, International Taxation 3(1)(2), New Delhi. Ld. AR further submits that assessee was a non-resident and this facts was duly disclosed in the return of income as well as accepted by the Department in the intimation order passed

DCIT, New Delhi vs. Newbury Holding Ltd., New Delhi

In the result, the appeals of the Revenue in ITA Nos

ITA 5335/DEL/2015[2008-09]Status: DisposedITAT Delhi19 Sept 2025AY 2008-09

Bench: S. Rifaur Rahman & Shri Yogesh Kumar U.S.

Section 124(4)Section 132Section 144CSection 147Section 148Section 151Section 6(3)(ii)

Assessing Officer had no jurisdiction to issue notice under section 148 of the Act by wrongly holding that the assessee company was a non-resident entity. 6. The Ld. Commissioner of Income Tax (Appeals) has erred in holding the provisions of section 124(4) was applicable in this case ... Assessee being a foreign company is a resident in India u/s 6(3) of the Act and even if the foreign company is non-resident in India, they will still be liable for tax in India u/s 9(1) of the Act. Accordingly, Ld. A.O. passed an assessment orders