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of <h1>Section 6 keeps 182-day and 60/365 residence tests, adds income-based deeming rule (Rs.15 lakh) and POEM company residence</h1> Section 6 retains 182-day and 60/365 residence tests, adds a deeming rule capturing individuals not taxable elsewhere with total income over Rs.15 lakh, and defines company residence via place of effective management (POEM). Compared with the Bill as introduced, the As Passed clarifies that the visiting citizen/PIO exception to the 60/365 test is subject to the income-based modification (raising 60 days to 120 days if income exceeds Rs.15 lakh), fixes minor drafting/typographical issues, and slightly refines deeming language. Substance is largely unchanged; practical impact is greater clarity and increased exposure for higher-income short-term visitors.
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