Schedule IV — INCOME NOT TO BE INCLUDED IN TOTAL INCOME OF ELIGIBLE NON- RESIDENTS, FOREIGN COMPANIES AND OTHER SUCH PERSONS

[See section 11]
INCOME NOT TO BE INCLUDED IN TOTAL INCOME OF ELIGIBLE NON-
RESIDENTS, FOREIGN COMPANIES AND OTHER SUCH PERSONS
In computing the total income of a tax year of any eligible person mentioned in
column C of the Table below, the income mentioned in column B of the said Table
shall not be included, subject to the conditions mentioned in column D of the said
Table, and the expressions used in columns B to D shall have the meanings respec-
tively assigned to them in the Notes below the said Table:
TABLE
Sl.
No.
Income not to be
included in total
income
Eligible persons Conditions
A B C D
1. Any income by way of
interest.
( a) A person being an
individual, who
is a resident out-
side India as de -
fined in section
2(w) of the For -
eign Exchange
Management
Act, 1999 (42 of
1999); or
( b) a person being
an individual
who has been
permitted by the
Such interest is on moneys
standing to the credit of
such person in a Non-Res-
ident (External) Account in
any bank in India as per the
said Act and the rules made
thereunder.
Sl.
No.
Income not to be
included in total
income
Eligible persons Conditions
A B C D
Reserve Bank of
India to maintain
the said account.
2. Any remuneration
received for service
in the capacity as an
official mentioned in
column C, not being a
citizen of India.
An official, by whatev-
er name called, of an
embassy, high commis-
sion, legation, commis-
sion, consulate or the
trade representation of
a foreign State, or as a
member of the staff of
any of these officials.
( a) The remuneration re-
ceived as a trade com-
missioner or other
official representative
in India of the gov -
ernment of a foreign
State (not holding
office as such in an
honorary capacity),
or as members of the
staff, if any, of the
government, resident
for similar purposes
in the country con -
cerned enjoy a similar
exemption in that
country; and
( b) the members of the
staff are subjects of
the country repre -
sented and are not
engaged in any busi -
ness or profession or
employment in India
otherwise than as
members of such staff.
3. Any remuneration re-
ceived as an employee
for services rendered
by him during his stay
in India.
A person who is an
employee of a foreign
enterprise, not being a
citizen of India.
( a) The foreign enterprise
is not engaged in any
trade or business in
India;
( b) his stay in India does
not exceed in the
aggregate a period of
ninety days in such
tax year; and
( c) such remuneration
is not liable to be
deducted from the in
Sl.
No.
Income not to be
included in total
income
Eligible persons Conditions
A B C D
come of the employer
chargeable under this
Act.
4. Any income charge -
able under the head
“Salaries”, received or
due as remuneration
for services rendered
in connection with
his employment on a
foreign ship.
Any individual being a
non-resident, not being
a citizen of India.
The total stay of such in -
dividual in India does not
exceed in the aggregate a
period of ninety days in the
tax year.
5. Any remuneration re-
ceived as an employee
of the Government of
a foreign State.
An employee of the
Government of a for -
eign State, not being a
citizen of India.
Such remuneration is re -
ceived during his stay in
India in connection with his
training in any establish -
ment or office of, or in any
undertaking owned by—
( a) the Government; or
( b) any company in
which the entire paid-
up share capital is
held by the Central
Government or any
State Government or
State Governments,
or partly by the Cen -
tral Government and
partly by one or more
State Governments;
or
( c) any company which
is a subsidiary of a
company referred to
in clause (b); or
( d) any corporation es -
tablished by or under
a Central Act or State
Act or Provincial Act;
or
( e) any society registered
under the Societies
Sl.
No.
Income not to be
included in total
income
Eligible persons Conditions
A B C D
Registration Act,
1860 (21 of 1860),
or under any other
law and wholly fi -
nanced by the Central
Government, or any
State Government or
State Governments,
or partly by the Cen -
tral Government and
partly by one or more
State Governments.
6. Any income arising by
way of royalty or fees
for technical services.
Any foreign company. ( a) Such company is no-
tified by the Central
Government; and
( b) such income is re -
ceived in pursuance
of an agreement en -
tered into with the
Central Government
for providing services
in or outside India in
projects connected
with security of India.
7. Any income arising by
way of royalty from,
or fees for technical
services rendered in
or outside India.
A non-resident, not
being a company, or a
foreign company.
( a) Such royalty is
received from the
National Technical
Research Organisa -
tion; or
( b) such fees is for tech -
nical services ren -
dered to the National
Technical Research
Organisation.
8. Interest received. Non-resident or a per-
son who is not ordi -
narily resident.
Such interest is received in
India on a deposit made on
or after the 1st April, 2005
in an Offshore Banking Unit
referred to in section 2( u)
of the Special Economic
Zones Act, 2005 (28 of
2005).
Sl.
No.
Income not to be
included in total
income
Eligible persons Conditions
A B C D
9. Income from lease
rentals, by whatever
name called, of cruise
ship.
Foreign company. ( a) Such income is re -
ceived from a speci -
fied company which
operates such ship or
ships in India;
( b) such foreign compa -
ny and the specified
company are sub -
sidiaries of the same
holding company;
and
( c) such income is re -
ceived or accrues or
arises in India for any
relevant tax year be -
ginning on or before
the 1st April, 2029.
10. Any income derived
in India by way of
interest, dividends or
Capital gains from
investments made.
The European Eco -
nomic Community.
Such investments are made
out of its funds under such
scheme as the Central
Government may, by noti-
fication specify.
11. Any income received
in India in Indian
currency.
A 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
in this behalf, to any
person in India;
( b) receipt of such income
in India by the foreign
company is pursuant
to an agreement or an
arrangement entered
into by the Central
Government or ap -
proved by the Central
Government;
( c) such foreign company
and the agreement or
Sl.
No.
Income not to be
included in total
income
Eligible persons Conditions
A B C D
arrangement is no -
tified 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.
12. Any 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 resi-
dent in India.
A foreign company. ( a) Such storage and
sale by the foreign
company is pursuant
to an agreement or an
arrangement entered
into by the Central
Government or ap -
proved by the Central
Government; and
( b) such foreign company
and the agreement or
arrangement is no -
tified by the Central
Government, having
regard to the national
interest.
13. Any income accruing
or arising on account
of sale of leftover
stock of crude oil, if
any, from the facili -
ty in India after the
expiry of the agree -
ment or arrangement
referred to against
serial number 12 or
on termination of the
said agreement or
arrangement.
A foreign company. Such 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.
39[13A. Any income arising
on account of pro -
viding capital goods,
equipment or tooling
to a contract manu-
A foreign company, who
is providing capital
goods, equipment or
tooling to the contract
manufacturer for use in
(a) Ownership of such
capital goods, equip -
ment or tooling re -
mains with the foreign
company;
39. Sl. Nos. 13A, 13B and 13C inserted by the Finance Act, 2026, w.e.f. 1-4-2026.
Sl.
No.
Income not to be
included in total
income
Eligible persons Conditions
A B C D
facturer, being a com-
pany resident in India.
electronic manufactur-
ing in India.
( b) such capital goods,
equipment or tooling is
under the control and
direction of the con -
tract manufacturer;
(c) the contract manufac-
turer 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 manufac-
turer produces elec -
tronic goods on behalf
of the foreign company
for a consideration;
(e) such exemption shall
be available up to the
tax year 2030-2031.
13B. Any income which
accrues or arises out -
side India, and is not
deemed to accrue or
arise in India.
An individual, being a
non-resident for a peri-
od 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 be -
yond 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.
13C. Any income accruing
or arising in India
A foreign company. (a) Such foreign compa -
ny is notified by the
Sl.
No.
Income not to be
included in total
income
Eligible persons Conditions
A B C D
or deemed to accrue
or arise in India by
way of procuring data
centre services from a
specified data centre.
Central Government
in this behalf;
(b) such foreign company
does not own or oper-
ate any of the physical
infrastructure or any
resources of the spec-
ified data centre;
(c) all sales by such for -
eign company to users
located in India are
made through a re -
seller entity being an
Indian company;
(d) such foreign com -
pany maintains and
furnishes such infor -
mation 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.]
14. Any 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.
Note 1.—For the purposes of Sl. No. 9,––
( a) “specified company” means any company, other than a domestic company which
operates cruise ships in India and opts to pay tax as per the provisions of section
61(2) (Table: Sl. No. 2);
( b) “holding company”, in relation to a foreign company or a specified company,
means a company of which such companies are subsidiary companies; and
( c) “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.
Note 2: For the purposes of Sl. No. 10,––
“European Economic Community” means the European Economic Community
established by the Treaty of Rome of 25th March, 1957.
40[Note 3: For the purposes of Sl. No. 13C,––
( a) “data centre” means a dedicated secure space within a building or centralised loca-
tion where computing and networking equipment is concentrated for the purpose
of collecting, storing, processing, distributing or allowing access to large amounts
of data;
( b) “data centre services” means the services provided by a data centre through the use
of physical infrastructure including land, buildings, mechanical electrical power
equipments, 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;
( c) “specified data centre” means a data centre which is––
( i) set up under an approved scheme and is 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.]