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nism-series-xb-section-6-1a-deemed-resident-provision[ INVESTMENT ADVISER (LEVEL 2) ]

Under Section 6(1A) of the Income Tax Act introduced in FY 2020-21, when is an Indian citizen deemed to be a 'Resident but Not Ordinarily Resident' (RNOR) in India, even if their physical stay in India is ZERO days during the financial year?

[ A ]If they hold an Indian PAN card and trade in cryptocurrency
[ B ]If they are employed by the United Nations in Geneva
[ C ]If their total Indian-source income (excluding foreign income) exceeds Rs. 15 Lakhs and they are not liable to tax in any other country by reason of domicile or residence (e.g., residing in a tax-free Gulf country)[ CORRECT ]
[ D ]Only if they own agricultural land in Punjab
Takeaway

Under Section 6(1A), an Indian citizen with over Rs. 15 Lakhs of India-source income who is not liable to tax anywhere else by reason of domicile or residence is deemed RNOR even with zero days of physical stay in India, so option C is correct.

Derivation
Section 6(1A), introduced from FY 2020-21, closes a loophole where high-net-worth Indian citizens could structure their affairs to avoid tax residency anywhere in the world (commonly by residing in a zero-income-tax Gulf jurisdiction) while still earning substantial India-source income. If such a citizen's Indian-source income (excluding foreign income) exceeds Rs. 15 Lakhs in the year and they are not taxable elsewhere by reason of domicile/residence, they are deemed a 'Resident but Not Ordinarily Resident,' bringing that Indian income properly within India's tax net regardless of physical presence. This tests recognition of this specific, targeted anti-avoidance provision, distinct from the general days-based residency tests under Section 6(1).
Why the others fail
A — If they hold an Indian PAN card and trade in cryptocurrency
Holding an Indian PAN card or trading in cryptocurrency has no bearing on triggering deemed residency under Section 6(1A).
B — If they are employed by the United Nations in Geneva
United Nations personnel are governed by specialized diplomatic and international-organization immunities, not the standard Section 6(1A) deemed residency test.
D — Only if they own agricultural land in Punjab
Ownership of agricultural land in any Indian state has no relation to the Section 6(1A) deemed residency rule, which turns on income level and foreign tax liability.