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Budget Byte – Key Budget Proposals for Non-Residents

Budget Byte – Key Budget Proposals for Non-Residents


  • Tax Incentives to International Financial Services Centre

Over the past few years several tax concessions have been provided to units located in International Financial Services Centre (IFSC) under the Act to make it a global hub of financial services sector. In order to further incentivize operations from IFSC, it is proposed to provide the following

    1. Extension of date for transfer of assets of the original fund, or of its wholly owned special purpose vehicle, to a resultant fund in case of relocation and transfer by a shareholder (or unitholder or interest holder) of a capital asset being a share (or unit or interest) held by him in the original fund in consideration for the share (or unit or interest) in the resultant fund shall not be considered as a transfer for the purpose of capital gains to 31st March, 2025 from current limitation of 31st March, 2023.
    2. Exemption to any income distributed on the offshore derivative instruments (ODI), entered into with an offshore banking unit (OBU) of an International Financial Services Centre (IFSC).


  • Extending deeming provision under section 9 to gift to not-ordinarily resident


    1. Finance (No. 2) Act, 2019 enacted to provide that the any sum of money exceeding fifty thousand rupees, received by a non-resident without consideration from a person resident in India, on or after the 5th day of July, 2019, shall be income deemed to accrue or arise in India. Now the scope is further proposed to be extended and covered gift received from Not-ordinarily resident (NOR).
    2. This amendment will take effect from 1st April, 2024 and will accordingly apply to assessment year 2024-25 and subsequent assessment years.


  • Amendments in TP Provisions


    1. Time limit for submission of TP Report asked by Assessing Officer (AOs) or the Commissioner (Appeals) during the course of any proceedings has been proposed to be reduced from 30 day to 10 days effective from 1st April, 2023.
    2. Specified domestic transactions proposed to include the transaction between the Cooperative society and the other person with close connection effective from 1st April, 2024.


  • Extending the scope for deduction of tax at source to lower or nil rate to non-Residents

Lower or nil rate of deduction of tax at source is proposed to be extended to non-resident unit holders receiving interest income from business trust effective from 1st April, 2023.

  • No carry forward of losses allowed to non-residents engaged in certain activities

Non-residents engaged in the business of providing services or facilities in connection with, or supplying plant and machinery on hire used, or to be used, in the prospecting for, or extraction or production of, mineral oils and in the business of civil construction or the business of erection of plant or machinery or testing or commissioning thereof, in connection with a turnkey power project approved by the Central Government who declares profits and gains of business for any previous year in accordance with the provisions of presumptive taxation under Section 44BB and Section 44BBB are not allowed to set off of unabsorbed depreciation and brought forward loss for such previous year.

  • dsrvindia.com

CA Sanjay Agrawal

CA Utkarsh Agrawal


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