How the RNOR engine is checked
Most residency calculators ask you to trust the answer. This page shows the working. Below are the 13 boundary cases our engine is tested against — the exact points in Section 6 of the Income-tax Act, 1961 where one day, or one rupee, changes the verdict.
Every verdict on this page was produced by running the same engine that powers the calculator over these cases when this page was built. Nothing here is a hand-written description of what the code is supposed to do. If the engine changed, this page changed with it — and the test suite would have failed first.
The Act boundary
All 13 fixtures produce the same verdict in FY 2025-26 and tax year 2026-27. The detailed cases below use the 1961 Act; the verified 2025 counterparts are:
- Income-tax Act, 2025 s.6(13)
- Income-tax Act, 2025 s.6(7)
Engine output vs. expected
13 of 13 cases match; 0 warnings
Each case declares the verdict and the sections it should produce. The figures above compare that declaration against what the engine actually returned at build time. Any number other than 13 of 13 means the engine and its specification have diverged, and should be treated as a defect on our side.
- NR
Case 1
NRI with no India presence
Indian citizen, 0 days in India this FY, no India-source income.
- Indian citizen
- Yes
Engine verdict
Non-Resident
No clause cited — no residency test is satisfied.
- Default §6(1)(c) threshold of 60 days applies.
- Section 6(1) states: neither the 182-day limb nor the 60-day + 365-day limb is met (0 days this FY, 0 days in preceding 4 FYs) → not resident under §6(1).
- No deemed-residence rule triggers → status is Non-Resident.
Why this case: The floor case. Neither limb of §6(1) is met and §6(1A) has nothing to bite on, so the answer must be a plain Non-Resident with no clause cited.
- RNOR
Case 2
Returnee, long NRI history
Indian citizen returning, 200 days in India, non-resident in all 10 preceding FYs.
- Days in India, this FY
- 200
- Non-resident years, 10 preceding FYs
- 10
- Indian citizen
- Yes
Engine verdict
Resident but Not Ordinarily Resident
§6(1)(a)§6(6)(a)- Default §6(1)(c) threshold of 60 days applies.
- Section 6(1)(a) states: present in India for 182 days or more in the FY → condition met (200 ≥ 182).
- Section 6(6)(a), first limb, states: an individual is Not Ordinarily Resident if non-resident in India in 9 out of the 10 previous years preceding that year (you indicated 10) → condition met.
Why this case: Resident on the 182-day limb, then carved out by the first limb of §6(6)(a). This is the ordinary first year back for a long-term NRI.
- RNOR
Case 3
Returnee, short NRI history but low day count
Indian citizen returning, 200 days in India, non-resident in only 2 of the 10 preceding FYs, 700 days in India across the 7 preceding FYs.
- Days in India, this FY
- 200
- Days in India, 7 preceding FYs
- 700
- Non-resident years, 10 preceding FYs
- 2
- Indian citizen
- Yes
Engine verdict
Resident but Not Ordinarily Resident
§6(1)(a)§6(6)(a)- Default §6(1)(c) threshold of 60 days applies.
- Section 6(1)(a) states: present in India for 182 days or more in the FY → condition met (200 ≥ 182).
- Section 6(6)(a), second limb, states: an individual is Not Ordinarily Resident if their stay in India during the 7 previous years preceding that year amounts to 729 days or less (you indicated 700) → condition met.
Why this case: Fails the nine-year limb of §6(6)(a) but passes its 729-day limb. Pins that the two limbs are alternatives, not cumulative conditions.
- ROR
Case 4
Returnee who fails both §6(6)(a) limbs
Indian citizen, 200 days in India, non-resident in only 2 of the 10 preceding FYs, 800 days in India across the 7 preceding FYs.
- Days in India, this FY
- 200
- Days in India, 7 preceding FYs
- 800
- Non-resident years, 10 preceding FYs
- 2
- Indian citizen
- Yes
Engine verdict
Resident and Ordinarily Resident
§6(1)(a)- Default §6(1)(c) threshold of 60 days applies.
- Section 6(1)(a) states: present in India for 182 days or more in the FY → condition met (200 ≥ 182).
- Neither limb of §6(6)(a) is satisfied (2 NR years in the 10 preceding FYs is fewer than 9, and 800 days in the 7 preceding FYs is more than 729) → status is Resident and Ordinarily Resident.
Why this case: Resident under §6(1)(a) with no §6(6) carve-out available, so worldwide income is taxable. Pins that RNOR is not automatic on return.
- RNOR
Case 5
High-income visitor, 120-day rule
Indian citizen visiting India, 150 days this FY, 400 days across the 4 preceding FYs, ₹20 lakh of non-foreign-source income.
- Days in India, this FY
- 150
- Days in India, 4 preceding FYs
- 400
- Days in India, 7 preceding FYs
- 800
- Indian citizen
- Yes
- On a visit to India
- Yes
- Income other than from foreign sources
- ₹20 lakh
Engine verdict
Resident but Not Ordinarily Resident
§6(1)(c)§6(6)(c)- Explanation 1(b) to §6(1): for a citizen/PIO visiting India whose total non-foreign-source income for the FY exceeds ₹15 lakh, the 60-day limb is replaced by 120 days.
- Section 6(1)(c) states: present in India for 120 days or more in the FY AND 365 days or more in the preceding 4 FYs → condition met (150 ≥ 120 and 400 ≥ 365).
- Section 6(6)(c) states: a citizen/PIO visiting India who is resident under the 120-day high-income limb is treated as Not Ordinarily Resident → condition met.
Why this case: Income above ₹15 lakh drops the visitor threshold from 182 days to 120 under Explanation 1(b), making 150 days enough for residence — and §6(6)(c) then makes that residence RNOR rather than ROR.
- NR
Case 6
Same visitor, income below the threshold
Identical to case 5, except non-foreign-source income is ₹10 lakh.
- Days in India, this FY
- 150
- Days in India, 4 preceding FYs
- 400
- Days in India, 7 preceding FYs
- 800
- Indian citizen
- Yes
- On a visit to India
- Yes
- Income other than from foreign sources
- ₹10 lakh
Engine verdict
Non-Resident
No clause cited — no residency test is satisfied.
- Explanation 1(b) to §6(1): for a citizen/PIO visiting India whose total non-foreign-source income for the FY does not exceed ₹15 lakh, the 60-day limb is replaced by 182 days.
- Section 6(1) states: neither the 182-day limb nor the 182-day + 365-day limb is met (150 days this FY, 400 days in preceding 4 FYs) → not resident under §6(1).
- No deemed-residence rule triggers → status is Non-Resident.
Why this case: Below ₹15 lakh the visitor threshold stays at 182 days, so the same 150-day stay is not residence at all. This is the pair that isolates the income test from the day count.
- RNOR
Case 7
Deemed resident, stateless for tax
Indian citizen, 0 days in India, ₹20 lakh of non-foreign-source income, not liable to tax in any other country.
- Indian citizen
- Yes
- Income other than from foreign sources
- ₹20 lakh
- Liable to tax in another country
- No
Engine verdict
Resident but Not Ordinarily Resident
§6(1A)§6(6)(d)- Default §6(1)(c) threshold of 60 days applies.
- Section 6(1) states: neither the 182-day limb nor the 60-day + 365-day limb is met (0 days this FY, 0 days in preceding 4 FYs) → not resident under §6(1).
- Section 6(1A) states: an Indian citizen with total non-foreign-source income exceeding ₹15 lakh in the FY who is not liable to tax in any other country by reason of domicile/residence or similar criterion is deemed resident in India → condition met.
- Section 6(6)(d) states: a person who is resident solely by virtue of §6(1A) is treated as Not Ordinarily Resident → condition met.
Why this case: Zero days in India and still resident. §6(1A) deems residence on citizenship plus income plus the absence of tax liability abroad, and §6(6)(d) makes that residence RNOR.
- NR
Case 8
Same person, liable to tax abroad
Identical to case 7, except liability to tax abroad has been established independently. A tax-residency certificate alone is not evaluated by this engine.
- Indian citizen
- Yes
- Income other than from foreign sources
- ₹20 lakh
Engine verdict
Non-Resident
No clause cited — no residency test is satisfied.
- Default §6(1)(c) threshold of 60 days applies.
- Section 6(1) states: neither the 182-day limb nor the 60-day + 365-day limb is met (0 days this FY, 0 days in preceding 4 FYs) → not resident under §6(1).
- No deemed-residence rule triggers → status is Non-Resident.
Why this case: The established foreign-liability input switches §6(1A) off. The engine accepts that legal fact; it does not determine foreign liability from nationality, a certificate or a zero tax bill.
- RNOR
Case 9
PIO visitor at 130 days
Person of Indian origin (not a citizen) visiting India, 130 days this FY, 400 days across the 4 preceding FYs, ₹16 lakh of non-foreign-source income.
- Days in India, this FY
- 130
- Days in India, 4 preceding FYs
- 400
- Days in India, 7 preceding FYs
- 800
- Person of Indian origin / OCI
- Yes
- On a visit to India
- Yes
- Income other than from foreign sources
- ₹16 lakh
Engine verdict
Resident but Not Ordinarily Resident
§6(1)(c)§6(6)(c)- Explanation 1(b) to §6(1): for a citizen/PIO visiting India whose total non-foreign-source income for the FY exceeds ₹15 lakh, the 60-day limb is replaced by 120 days.
- Section 6(1)(c) states: present in India for 120 days or more in the FY AND 365 days or more in the preceding 4 FYs → condition met (130 ≥ 120 and 400 ≥ 365).
- Section 6(6)(c) states: a citizen/PIO visiting India who is resident under the 120-day high-income limb is treated as Not Ordinarily Resident → condition met.
Why this case: The 120-day branch is not limited to citizens. Pins that a PIO — including an OCI cardholder — is caught by Explanation 1(b) and §6(6)(c) on the same terms.
- ROR
Case 10
No carry-over between evaluations
The same inputs as case 4, evaluated on its own.
- Days in India, this FY
- 200
- Days in India, 7 preceding FYs
- 800
- Non-resident years, 10 preceding FYs
- 2
- Indian citizen
- Yes
Engine verdict
Resident and Ordinarily Resident
§6(1)(a)- Default §6(1)(c) threshold of 60 days applies.
- Section 6(1)(a) states: present in India for 182 days or more in the FY → condition met (200 ≥ 182).
- Neither limb of §6(6)(a) is satisfied (2 NR years in the 10 preceding FYs is fewer than 9, and 800 days in the 7 preceding FYs is more than 729) → status is Resident and Ordinarily Resident.
Why this case: A deliberate duplicate. The engine holds no state between calls, so an identical question must return an identical answer regardless of what was asked before it.
- RNOR
Case 11
Exactly 182 days
Indian citizen, exactly 182 days in India, no prior residence and 0 days across the 7 preceding FYs.
- Days in India, this FY
- 182
- Indian citizen
- Yes
Engine verdict
Resident but Not Ordinarily Resident
§6(1)(a)§6(6)(a)- Default §6(1)(c) threshold of 60 days applies.
- Section 6(1)(a) states: present in India for 182 days or more in the FY → condition met (182 ≥ 182).
- Section 6(6)(a), second limb, states: an individual is Not Ordinarily Resident if their stay in India during the 7 previous years preceding that year amounts to 729 days or less (you indicated 0) → condition met.
Why this case: The §6(1)(a) boundary is "182 days or more", so 182 is inside it, not outside. One day either way changes the verdict.
- RNOR
Case 12
Exactly 729 days across the preceding 7 FYs
Indian citizen, 200 days in India this FY, non-resident in 2 of the 10 preceding FYs, exactly 729 days across the 7 preceding FYs.
- Days in India, this FY
- 200
- Days in India, 7 preceding FYs
- 729
- Non-resident years, 10 preceding FYs
- 2
- Indian citizen
- Yes
Engine verdict
Resident but Not Ordinarily Resident
§6(1)(a)§6(6)(a)- Default §6(1)(c) threshold of 60 days applies.
- Section 6(1)(a) states: present in India for 182 days or more in the FY → condition met (200 ≥ 182).
- Section 6(6)(a), second limb, states: an individual is Not Ordinarily Resident if their stay in India during the 7 previous years preceding that year amounts to 729 days or less (you indicated 729) → condition met.
Why this case: The §6(6)(a) day limb reads "729 days or less", so 729 still qualifies for RNOR and 730 does not. This is the single day that separates RNOR from worldwide taxation.
- RNOR
Case 13
Exactly 60 days plus 365 days
Indian citizen, not a visitor and not leaving for employment, exactly 60 days in India this FY and exactly 365 days across the 4 preceding FYs.
- Days in India, this FY
- 60
- Days in India, 4 preceding FYs
- 365
- Days in India, 7 preceding FYs
- 365
- Indian citizen
- Yes
Engine verdict
Resident but Not Ordinarily Resident
§6(1)(c)§6(6)(a)- Default §6(1)(c) threshold of 60 days applies.
- Section 6(1)(c) states: present in India for 60 days or more in the FY AND 365 days or more in the preceding 4 FYs → condition met (60 ≥ 60 and 365 ≥ 365).
- Section 6(6)(a), second limb, states: an individual is Not Ordinarily Resident if their stay in India during the 7 previous years preceding that year amounts to 729 days or less (you indicated 365) → condition met.
Why this case: Both halves of the §6(1)(c) limb sit exactly on their thresholds, and both read "or more". Residence follows, then the §6(6)(a) day limb makes it RNOR.
The sections, in full
Quoted from the bare Act as published by the Income Tax Department, so you can check each verdict above against the words it rests on. Section 6, Income-tax Act 1961 ↗
- §6(1)(a)
- An individual is resident in India in any previous year if he is in India in that year for a period or periods amounting in all to one hundred and eighty-two days or more.
- §6(1)(c)
- An individual is resident in India if, having within the four years preceding that year been in India for a period or periods amounting in all to three hundred and sixty-five days or more, he is in India for sixty days or more in that year. The sixty-day figure is varied by Explanations 1(a) and 1(b).
- Explanation 1(a) to §6(1)
- For an Indian citizen who leaves India in any previous year as a member of the crew of an Indian ship, or for the purposes of employment outside India, the words "sixty days" are read as "one hundred and eighty-two days".
- Explanation 1(b) to §6(1)
- For an Indian citizen or person of Indian origin who, being outside India, comes on a visit to India, the words "sixty days" are read as "one hundred and eighty-two days" — or as "one hundred and twenty days" where their total income other than income from foreign sources exceeds fifteen lakh rupees in that year.
- §2(29A)
- "liable to tax", in relation to a person and with reference to a country, means that there is an income-tax liability on such person under the law of that country for the time being in force and shall include a person who has subsequently been exempted from such liability under the law of that country. Inserted by the Finance Act 2021 with effect from 1 April 2021; the clause previously numbered 2(29A), "long-term capital asset", was renumbered 2(29AA) at the same time.
- §6(1A)
- An individual, being a citizen of India, having total income, other than the income from foreign sources, exceeding fifteen lakh rupees during the previous year shall be deemed to be resident in India in that previous year, if he is not liable to tax in any other country or territory by reason of his domicile or residence or any other criteria of similar nature.
- §6(6)(a)
- A person is said to be "not ordinarily resident" in India in any previous year if such person is an individual who has been a non-resident in India in nine out of the ten previous years preceding that year, or has during the seven previous years preceding that year been in India for a period of, or periods amounting in all to, seven hundred and twenty-nine days or less.
- §6(6)(c)
- A person is said to be "not ordinarily resident" if such person is a citizen of India, or a person of Indian origin, having total income, other than the income from foreign sources, exceeding fifteen lakh rupees during the previous year, as referred to in clause (b) of Explanation 1 to clause (1), who has been in India for a period or periods amounting in all to one hundred and twenty days or more but less than one hundred and eighty-two days.
- §6(6)(d)
- A person is said to be "not ordinarily resident" if such person is a citizen of India who is deemed to be resident in India under clause (1A).
What this page does not claim
That the engine is right about every possible fact pattern. These are boundary cases — the edges where the statute changes its answer — not a complete model of Indian tax residency. Treaty tie-breakers, mid-year departures with an employer transition, split residence, and the contested treatment of UK non-doms on the remittance basis are all outside what is tested here. This is educational material, not advice; confirm your own position with a qualified Chartered Accountant.
What it does claim is narrower and checkable: on these 13 cases, the engine returns these verdicts, for these reasons, under these sections — and you did not have to take our word for any of it.
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Educational only. RebaseNest is not a SEBI-registered investment adviser and does not give tax, legal or investment advice. Rules change; confirm your position with a qualified chartered accountant before acting. Full disclaimer.
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- DTAA explained: How NRIs actually claim relief from double taxation
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