https://www.taxtmi.com/forum/issue?id=120714 Residential status under Section 6 of the Income-tax Act is ordinarily determined year by year on the basis of physical stay in the relevant previous year, applying the statutory day-count tests together with the applicable explanations. The commonly accepted view is that the concessional 182-day threshold for a citizen of India or person of Indian origin visiting India is linked to the facts of the relevant year and does not, on the statute's plain reading, require proof of non-resident status in earlier years unless the provision expressly says so. The Binny Bansal ITAT view is described as debatable, though it may increase litigation risk in borderline cases. en-us Wed, 14 Jan 2026 14:30:13 +0530 Wed, 13 May 2026 14:41:50 +0530 TaxTMI RSS Generator https://www.taxtmi.com/forum/issue?id=120714 Residential status under Section 6 of the Income-tax Act is ordinarily determined year by year on the basis of physical stay in the relevant previous year, applying the statutory day-count tests together with the applicable explanations. The commonly accepted view is that the concessional 182-day threshold for a citizen of India or person of Indian origin visiting India is linked to the facts of the relevant year and does not, on the statute's plain reading, require proof of non-resident status in earlier years unless the provision expressly says so. The Binny Bansal ITAT view is described as debatable, though it may increase litigation risk in borderline cases. Discussion-Forum Income Tax Wed, 14 Jan 2026 14:30:13 +0530 https://www.taxtmi.com/forum/issue?id=120714