Ms. Kavya Iyer, a citizen of India, lives and works in Dubai. In tax year 2026-27 she comes on a visit…

Because her income other than from foreign sources exceeds fifteen lakh rupees, section 6(5) applies the test in section 6(2)(b) with 120 days, which she meets with 130 days in the year and 400 days in the four preceding years, so she is resident. Section 6(13)(b) then makes such a citizen not ordinarily resident where she was in India for 120 days or more but less than 182 days, so she is "Resident but not ordinarily resident in India". Her tax position in Dubai does not matter, because section 6(8) excludes the deemed residence rule for a person already resident under section 6(2) to (6).