Foreign business income accrues and is first received outside India. The business is controlled from India, and the income is not deemed to accrue in India. Which individuals include the income in…

Under section 5(1)(c) of the Income-tax Act, 2025, a resident includes income accruing outside India, but a person not ordinarily resident under section 6(13) includes it only when it is derived from a business controlled in or a profession set up in India, which is the case here. A non-resident is taxed under section 5(2) only on income received or accruing in India, so it is not taxed on this income.