Untangling Seven Years of Unfiled India Tax Returns
A professional returning from nine years in Singapore feared seven years of unfiled India returns would derail his new job. A year-by-year residency analysis showed the reality was far more manageable.
What the engagement demanded.
An Indian professional who had worked in Singapore for nine years was planning to move back to Mumbai and join a domestic financial services firm. When he started the process, he realised he had not filed India tax returns for seven of those years, assuming as a non-resident with no India income he had no obligation. His new employer’s HR flagged that the background check process would surface outstanding returns, and his CA in Singapore told him to speak to someone in India, which is how he came to NDSA.
How we executed the engagement.
Residency Determination
Pulled his residential status year by year using FEMA and Income Tax Act criteria, confirming he was RNOR or NR with no India-source income for most years — and therefore no mandatory filing obligation.
Identifying Real Liability
Isolated the two years where he had India-source income from interest on NRO deposits, which did require returns.
Return Filing with Treaty Relief
Filed both returns with correct income disclosure and relief claimed under the India-Singapore tax treaty.
Residency Memo
Prepared a clear residency status memo he could share with his new employer to explain the non-filing history.
The capabilities we brought to bear.
Year-by-Year Residency Analysis
Residential status determined under both FEMA and Income Tax Act criteria for each of the nine years.
Tax Treaty Relief
Relief claimed under the India-Singapore Double Taxation Avoidance Agreement on the years with genuine liability.
NRO Income Disclosure
Correct disclosure of India-source interest income from NRO deposits.
Employer-Facing Documentation
A residency status memo prepared to satisfy the new employer’s compliance team.
The results we delivered.
Only two of the seven years carried a genuine filing obligation. Both were filed and assessed cleanly — with interest, but no penalty.
Non-residents often assume the worst about years of unfiled returns. The reality is usually more manageable once the residency status for each year is established correctly, and that analysis takes a few days, not months.
