Special tax rate on offshore banking and IFSC unit income under a bifurcated income-tax computation rule. Tax on business income of an Offshore Banking Unit or International Financial Services Centre unit is computed under a special bifurcated rate structure where income referred to in section 147(3) is taxed at 15%, and the balance of total income is taxed at the rates in force. The provision falls within the special provisions relating to non-residents and foreign companies. A note records that the section was substituted by the Finance Act, 2026, and the earlier text allowed a non-resident Indian to opt out of sections 212 to 217 for a tax year through a declaration in the return of income.