Section 211 — Sportsman NR Non-Citizen 20pc | ITA 2025

Section 211 — - TAX ON SPORTSMAN / ATHLETE NR-NON-CITIZEN

Section 211 is the substantive equivalent of 1961 s. 115BBA -- the special rate provision for SPORTSMEN (including ATHLETES) AND SPORTS ASSOCIATIONS / INSTITUTIONS who are NON-RESIDENT AND NON-CITIZEN of India. Income covered: (a) Game-participation in India (match fees / appearance fees); (b) Advertisement participation; (c) Contribution to articles relating to game / sport in newspapers / journals. RATE: 20% flat. Conditions: no deduction for expenditure / allowance. CRITICAL FOR: foreign cricketers / footballers in IPL / ISL; foreign tennis players in Indian tournaments; foreign coaches / commentators.

Statutory text — Income-tax Act, 2025

Marginal note -- Tax on income of sportsman / athlete / sports association non-resident non-citizen

(1) Where the total income of an assessee,—

(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

(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

(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 aggregate of income-tax payable by the assessee shall be computed at the rate specified in the column C applied on the corresponding income specified in column B:—

TABLE Sl. Income Rate of Income- No. tax payable

A B C

1. Income referred to in clause (a) or (b) or (c). 20%

2. Total income as reduced by income referred to in clause Rates in force.

(a) or (b) or (c).

(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).

(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. Interpretation.

Corresponding provision — 1961 regime

INCOME-TAX ACT, 2025	INCOME-TAX ACT, 1961
INCOME-TAX ACT, 2025 -- s. 211	INCOME-TAX ACT, 1961 -- s. 115BBA
NR-non-citizen sportsman / sports association 20%	1961 s. 115BBA

ELIGIBILITY: (a) ASSESSEE: NON-RESIDENT (per s. 6) AND NOT a CITIZEN of India; OR sports association / institution (NR / non-citizen). (b) INCOME COVERED: (i) Income from PARTICIPATION in any GAME OR SPORT IN INDIA (match fees / tournament fees / appearance fees); (ii) ADVERTISEMENT income; (iii) CONTRIBUTION OF ARTICLES relating to game / sport in newspapers / journals. RATE: 20% flat + applicable surcharge + 4% cess. NO deduction for any expenditure / allowance. TYPICAL APPLICATION: (i) Foreign cricketers in IPL (e.g., Pat Cummins / Glenn Maxwell / Mitchell Starc) -- match fees taxable @ 20%; (ii) Foreign footballers in ISL; (iii) Foreign tennis players in Tata Open / India Open; (iv) Foreign cricket commentators in IPL / international tours; (v) Foreign coaches / staff with Indian sports leagues. DTAA INTERACTION: Article 17 (Artistes and Sportsmen) typically allows source-state taxation without limitation; rate often equivalent to or higher than treaty cap.

CROSS-REFERENCES

Section 6 -- Residence.
Section 9 -- Source-rule deeming.
Section 159 -- DTAA framework (Article 17).
Section 393 -- TDS on cross-border payments.

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