FEMA & International Tax

NRI Section 6 Residential Status: 182, 120 and 60-Day Tests

CA Nikhil Gupta·Aug 2026·7 min readFEMA & International Tax

Section 6 of the Income-tax Act, 2025 retains the 182-day and 60-day-plus-365-day tests, but Indian citizens leaving for employment, visiting citizens or…

Section 6 of the Income-tax Act, 2025 retains the 182-day and 60-day-plus-365-day tests, but Indian citizens leaving for employment, visiting citizens or PIOs with income above ₹15 lakh and deemed residents require special branches.

Legal or Computational Framework

What the search phrase hides

The phrase NRI residential status section 6 IT act compresses several legal questions into one line. The outcome cannot be trusted until the page identifies the relevant person, transaction, period, source document and statutory exception. A high-quality calculator should therefore show why an amount was accepted or rejected instead of displaying a black-box answer.

Governing framework

Residence is annual and fact-specific. A visitor with relevant Indian income not exceeding ₹15 lakh generally gets the 182-day substitution; above ₹15 lakh, 120 days plus 365 prior days can create residence. Deemed residence applies to specified Indian citizens not liable to tax elsewhere. NOR then limits foreign-income scope.

Tax Year 2026–27 means income earned from 1 April 2026 under the Income-tax Act, 2025. AY 2026–27 relates to FY 2025–26 and remains under the Income-tax Act, 1961.

Computation architecture

CheckWhat to verify
StatusResidence, treaty residence and taxpayer or enterprise identity
SourceIndia receipt, India accrual/deemed accrual and foreign source
TreatyArticle, PE/nexus, beneficial ownership and documentation
TaxNormal or special domestic rate compared with treaty
ComplianceTDS/TCS, forms, return and disclosure schedules

Step-by-step method

  1. Count exact India days.
  2. identify departure or visit status.
  3. compute relevant income excluding prescribed foreign-source income.
  4. test basic conditions.
  5. apply 182 or 120-day substitutions.
  6. test deemed residence.

Worked example

A PIO visits for 118 days with 500 preceding-four-year days and Indian income of ₹22 lakh: the 120-day limb is not met. At 125 days, it may be met, leading to NOR rather than ordinary NRI status.

The example is intentionally presented as a calculation trail. The final result must be recomputed when a date, residence test, holding period, asset classification, employee category, notification, treaty or source document changes.

Residence, source and treaty are three separate gates

A person or company can be non-resident yet have taxable Indian-source income. Conversely, a later transfer of foreign savings to India need not create taxable income. The correct sequence is residence first, domestic source second and treaty restriction third. Withholding is a collection mechanism after that analysis, not a substitute for it.

Cross-border evidence standard

Travel calendars, first-receipt bank records, contracts, tax-residence certificates, Form 10F, foreign tax certificates and beneficial-ownership evidence should reconcile with the return. Where the question involves PE, POEM, service days or an agent's authority, a narrative memo is more reliable than a single calculator field.

Edge cases that change the answer

Cross-check before filing, paying or claiming

  1. Confirm that the legal year and transaction date match the rate or rule used.
  2. Reconcile gross consideration, gross income or gross benefit—not merely the net bank receipt.
  3. Distinguish a deduction or exemption from TDS, TCS, withholding or an employer provision.
  4. Keep the original source document and a calculation worksheet.
  5. Review interactions with losses, special rates, surcharge, cess, treaty relief or GST.
  6. Record the official source and its effective date in the calculation output.

Calculator design standard

The Finin2min calculator linked below should retain the user's original input, display the legally accepted amount, identify the formula and rate, and state the reason for every cap or rejection. Rate-sensitive output should show the applicable tax year or effective date. Where facts cannot be automated—such as treaty PE, beneficial ownership, continuity of service or property valuation—the tool should flag professional review rather than make an unsupported assumption.

What Generic Pages Miss

  • Using a calendar year.
  • Counting only complete 24-hour stays.
  • Ignoring the ₹15 lakh test.
  • Assuming no foreign tax payment means deemed residence.
  • Forgetting NOR classification.

Generic pages also tend to mix a tax credit with a deduction, a labour entitlement with an income-tax exemption, or a supply value with business income. That can produce a mathematically neat but legally wrong result.

Practical Documentation Checklist

Related Calculator
Residential Status Checker
Open Calculator →

For the complete rules on this topic, see the core guide: RNOR Status for Returning NRIs.

See the broader FEMA, NRI & International Tax knowledge hub for related rules and calculators on this topic.

Finin2min Summary

Section 6 of the Income-tax Act, 2025 retains the 182-day and 60-day-plus-365-day tests, but Indian citizens leaving for employment, visiting citizens or PIOs with income above ₹15 lakh and deemed residents require special branches.

Finin2min rule: classify first, calculate second, and document every assumption.

Frequently Asked Questions

What is the basic test?
182 days, or 60 days plus 365 days in the preceding four years, before special substitutions.
When does 120 days matter?
For certain visiting Indian citizens or PIOs with relevant Indian income above ₹15 lakh.
Does leaving for employment use 182 days?
The special rule generally substitutes 182 days for the 60-day limb.
Can someone be deemed resident with zero India days?
The deemed-resident rule does not require the ordinary day test, but has citizenship, income and foreign-liability conditions.
What status does a 120-day resident get?
The law generally treats that category as not ordinarily resident if specified conditions are met.
Does the new Act erase old lookback years?
No. Earlier years continue to count for the four-, seven- and ten-year historical tests.

Source and review trail

Use the current official instrument, portal or regulator publication before acting. This panel separates the category authority from page-specific references.

Primary category
FEMA & International Tax
Official starting point
www.incometax.gov.in
Editorial review date
2026-08-02
Content status
Finin2min explanation; official source controls where facts, law, rates, forms or procedures can change.

Page source links