Tax on non-resident sportsmen or sports associations
[Section-211 as per the Income Tax Act, 2025 (this Act) w.e.f. 1st April, 2026.]
Section 211(1) of Income Tax Act 2025
211(1) Where the total income of an assessee,––
- 211(1)(a) being a sportsman (including an athlete), who is not a citizen of India and is a non-resident, includes any income received or receivable by way of––
- (i) participation in India in any game [other than a game the winnings from which are taxable as specified in section 194(1) (Table: Sl. No. 1)] or sport; or
- (ii) advertisement; or
- (iii) contribution of articles relating to any game or sport in India in newspapers, magazines or journals; or
- 211(1)(b) being a non-resident sports association or institution, includes any amount guaranteed to be paid or payable to such association or institution in relation to any game, other than a game the winnings from which are taxable as specified in section 194(1) (Table: Sl. No. 1) or sport played in India; or
- 211(1)(c) being an entertainer, who is not a citizen of India and is a non-resident, includes any income received or receivable from his performance in India,
then, the income-tax payable by the assessee shall be the aggregate of amounts mentioned in column C of the Table below:––
Table
| Income | Income-tax payable |
|---|---|
| Income referred to in clause (a) or (b) or (c). | 20 % |
| Total income as reduced by income referred to in clause (a) or (b) or (c). | Income-tax chargeable on such income. |
Section 211(2) of Income Tax Act 2025
211(2) No deduction in respect of any expenditure or allowance shall be allowed under any provision of this Act in computing the income referred to in sub-section (1).
Section 211(3) of Income Tax Act 2025
211(3) It shall not be necessary for the assessee to furnish a return of his income under section 263(1), if—
- (a) his total income during the tax year consisted only of income referred to in sub-section (1); and
- (b) the tax deductible at source under the provisions of Chapter XIX-B has been deducted from such income.
FAQs on Section 211 of Income Tax Act 2025
Who is liable to pay tax under Section 211(1)?
Non-resident sportsmen, non-resident sports associations or institutions, and non-resident entertainers are liable if they earn specified income from activities in India.
What types of income are covered for non-resident sportsmen?
Income from participation in games or sports in India (except those with winnings taxable under section 194(1)), advertisements, and contributions of articles in Indian publications.
Is income from advertisements included in taxable income for non-resident sportsmen?
Yes, any income received or receivable from advertisements is taxable under Section 211(1)(a)(ii).
What income is taxable for non-resident sports associations or institutions?
Any guaranteed amount paid or payable in connection with a game (excluding those in section 194(1)) or sport played in India.
Are entertainers also covered under this section?
Yes, non-resident entertainers who are not Indian citizens are taxed on income received or receivable from performances in India.
What is the tax rate applicable to the specified income?
The income tax payable is 20% on the income referred to in clause (a), (b), or (c).
Is any deduction allowed from such income?
No deduction in respect of any expenditure or allowance is permitted while computing income under Section 211(1), as per Section 211(2).
How is total income taxed under this provision?
Tax is computed in two parts: 20% on the income under clause (a), (b), or (c), and regular tax on the remaining total income after reducing this specific income.
Is filing a return of income mandatory for such assessees?
No, return filing is not required if their total income consists only of income under Section 211(1) and tax has been fully deducted at source under Chapter XIX-B.
What if the non-resident earns other income in India along with income under Section 211(1)?
In such a case, they may be required to file a return, and tax would be computed on both components as specified in the table under Section 211(1).
Does this section apply to winnings from games like lotteries or betting?
No, income from such games is excluded if they fall under the games specified in section 194(1) Table Sl. No. 1.
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