Comparison of Section 6 'Residence in India' between the Income-Tax Act, 2025 (as passed) and the Income-Tax Bill, 2025 (as originally introduced)

Residence in India: income-linked deeming now captures high-income returning citizens visiting short-term, and POEM defines company residence.

Section 6 prescribes residence tests combining day-count rules (182-day and 60/365 tests), categorical exceptions for ship crew and visiting citizens/PIOs, an income-linked modification that extends the shorter day-count threshold for higher-income returning citizens, a deeming rule capturing citizens not taxable elsewhere, company residence via Indian status or Place of Effective Management, and a deeming provision that applies residence across all income sources; As Passed drafting clarifies interplay between the visiting exception and income-based modification and contains minor typographical refinements.