The Statutory Brief

IT Act 1961 → 2025 / Section 10 clauses

Non-residents & DTAA

Section 10 clauses → Schedule IV

Diplomats, short-stay foreign employees, foreign ship crew, cruise lease rentals, crude oil — section 10 for non-residents

Section 10 clauses of the old Income-tax Act, 1961 · new Schedule IV under the Income-tax Act, 2025

New reference Section 11 read with Schedule IV (non-residents and foreign companies)

Income-tax Act, 1961Section 10 clauses

  • 10(6): foreign diplomats, short-stay foreign employees (≤ 90 days), foreign ship crew, trainees
  • 10(6A)–(6BB), 10(6C), 10(6D): tax borne on royalty/FTS and notified foreign company income
  • 10(15B): cruise ship lease rentals; 10(23BBB): EEC
  • 10(48)–(48B): crude oil sale and storage by foreign companies

Applies to FY 2025-26 (AY 2026-27) and earlier years.

Income-tax Act, 2025Section 11 read with Schedule IV (non-residents and foreign companies)

  • Schedule IV: eligible non-residents, foreign companies and similar persons
  • S.No. 3: foreign enterprise employee — stay not exceeding 90 days
  • S.No. 9: cruise ship lease rentals; S.No. 11–13: crude oil
  • S.No. 14: saving entry for old 10(6A), (6B), (6BB), (15A) and specified 10(15) interest; S.No. 13A–13C added by Finance Act 2026

Applies from tax year 2026-27 (from 1 April 2026).

Section-by-section mapping (13 sections)

1961 ActSubject2025 Act
10(6)(ii)Remuneration of foreign diplomats and consular staffSchedule IV S.No. 2
10(6)(vi)Foreign employee — short stay (90 days)Schedule IV S.No. 3
10(6)(viii)Non-resident crew of foreign shipsSchedule IV S.No. 4
10(6)(xi)Employees of foreign Government on trainingSchedule IV S.No. 5
10(6C)Royalty/FTS of notified foreign companies (security)Schedule IV S.No. 6
10(6D)Royalty/FTS from National Technical Research OrganisationSchedule IV S.No. 7
10(15B)Cruise ship lease rentalsSchedule IV S.No. 9
10(23BBB)European Economic Community investment incomeSchedule IV S.No. 10
10(48)Crude oil sale income received in Indian currencySchedule IV S.No. 11
10(48A)Crude oil storage in IndiaSchedule IV S.No. 12
10(48B)Sale of leftover crude oil stockSchedule IV S.No. 13
10(6A)/(6B)/(6BB)Tax paid on behalf of foreign companies/non-residents (saving clause)Schedule IV S.No. 14
10(15)(iiia)–(iv)(fa), 10(15A)Specified interest and lease payments (saving clause)Schedule IV S.No. 14

Source: CBDT mapping of sections, Income-tax Act 1961 to Income-tax Act 2025.

What changed

Renumbered into Schedule IV. Finance Act 2026 added S.No. 13A–13C (including electronics tooling and data centres), and a later 2026 amending Act added more entries.

Practice notes

  • NRE account interest (old 10(4)(ii)) has its own page.
  • Schedule IV relief does not apply automatically to a resident; check column C.

These are summaries, not the statutory text. Read the bare Act for both sections on the Income Tax Department's official site, which also has a side-by-side comparison utility.

Frequently asked

What is section 10(6)(ii) called in the new Income-tax Act, 2025?

Section 10(6)(ii) of the Income-tax Act, 1961 (Remuneration of foreign diplomats and consular staff) corresponds to section Schedule IV S.No. 2 of the Income-tax Act, 2025, which applies from 1 April 2026 (tax year 2026-27).

What is section 10(6)(vi) called in the new Income-tax Act, 2025?

Section 10(6)(vi) of the Income-tax Act, 1961 (Foreign employee — short stay (90 days)) corresponds to section Schedule IV S.No. 3 of the Income-tax Act, 2025, which applies from 1 April 2026 (tax year 2026-27).

What is section 10(6)(viii) called in the new Income-tax Act, 2025?

Section 10(6)(viii) of the Income-tax Act, 1961 (Non-resident crew of foreign ships) corresponds to section Schedule IV S.No. 4 of the Income-tax Act, 2025, which applies from 1 April 2026 (tax year 2026-27).

What is section 10(6)(xi) called in the new Income-tax Act, 2025?

Section 10(6)(xi) of the Income-tax Act, 1961 (Employees of foreign Government on training) corresponds to section Schedule IV S.No. 5 of the Income-tax Act, 2025, which applies from 1 April 2026 (tax year 2026-27).

What is section 10(6C) called in the new Income-tax Act, 2025?

Section 10(6C) of the Income-tax Act, 1961 (Royalty/FTS of notified foreign companies (security)) corresponds to section Schedule IV S.No. 6 of the Income-tax Act, 2025, which applies from 1 April 2026 (tax year 2026-27).

What is section 10(6D) called in the new Income-tax Act, 2025?

Section 10(6D) of the Income-tax Act, 1961 (Royalty/FTS from National Technical Research Organisation) corresponds to section Schedule IV S.No. 7 of the Income-tax Act, 2025, which applies from 1 April 2026 (tax year 2026-27).

What changed in sections 10(6), 10(6C), 10(15A)… under the new Income Tax Act?

Renumbered into Schedule IV. Finance Act 2026 added S.No. 13A–13C (including electronics tooling and data centres), and a later 2026 amending Act added more entries.

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