Comparison of SCHEDULE IV "INCOME NOT TO BE INCLUDED IN TOTAL INCOME OF ELIGIBLE NON-RESIDENTS, FOREIGN COMPANIES AND OTHER SUCH PERSONS" between the Income-Tax Act, 2025 (as passed) and the Income-Tax Bill, 2025 (as originally introduced)

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....on-residents, foreign companies and other persons (see section 11 reference). It matters for non-resident individuals and foreign entities interacting with India (embassies, foreign enterprises, foreign companies, European Economic Community etc.). Effective date or decision date: Not stated in the document. Background & Scope Statutory hook: SCHEDULE IV is framed under "See section 11" of the Bill. The Schedule sets out tabulated exemptions (column A: serial number; B: income not to be included; C: eligible persons; D: conditions). The Schedule covers diverse categories including interest on NRE accounts, diplomatic remuneration, employees of foreign enterprises, incomes linked to foreign ships, government trainees, royalties/fees for te....

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....d to maintain reciprocity for diplomatic personnel. The Schedule uses notification powers (Central Government) and pre-conditions (e.g., residence outside India, RBI permission, aggregate days of stay) as mechanisms to limit the benefit to particular factual situations. The text indicates that the exemption is conditional rather than absolute, requiring specified factual predicates and administrative notifications. Exceptions/Provisos Carve-outs and conditions appear in column D against each serial number. Notable conditions include: * Sl. No. 1: interest on moneys in a Non-Resident (External) Account in Indian banks as per FEMA and rules. * Sl. No. 2: diplomatic/trade commissioner exemption conditioned on reciprocity and staff status....

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....yer under the Act. (Consistent with Sl. No. 3.) * Example 3: A notified foreign company stores crude oil in India under a Central Government-approved arrangement and sells the oil to an Indian resident as per the agreement - the income accruing from storage and sale is not included in total income subject to notification. (Consistent with Sl. Nos. 12-13.) Interplay The Schedule expressly interacts with: FEMA, 1999 (residency definition and NR(E) accounts); Special Economic Zones Act, 2005 (Offshore Banking Units); and referenced sections of the Income-tax Act, 1961 for Sl. No. 14 exemptions. Several exemptions depend on Central Government notification or agreements entered into/approved by the Central Government, indicating administrati....

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....ication of the company and agreement slightly differently; both require Central Government notification and national-interest consideration. Substantively the scope of exemption is governed by Central Government notification; any difference is stylistic unless read to alter the sequencing of notification vs. entry of agreement - not expressly stated as a legal difference in the texts. * Formatting and small textual insertions: Document 2 contains a stray full stop after the clause in Sl. No. 7(b) and some additional bracket spacing in Sl. No. 14. * Practical impact: typographical; no substantive legal consequence discernible from the provided materials. Practical Implications * Compliance and risk areas: taxpayers and foreign entitie....