Tax Year 2025-26 · Income Tax Act 2025 · Updated June 2026

Purchasing Immovable Property from an NRI in India

A complete tax & compliance guide for buyers and NRI sellers — covering TDS obligations, capital gains, exemptions, FEMA repatriation, and real-world worked examples under the new Income Tax Act 2025.

Source: incometaxindia.gov.in
Section 393(2) | Section 195 | Section 84 | FEMA 1999
For Buyers & NRI Sellers
🏢 Indian Resident Buying from NRI
BUYER TDS ₹ INCOME TAX DEPARTMENT 🏛 Net ₹ NRI SELLER Buyer deducts TDS → Deposits to Govt → Net to NRI ✈️
💸 TDS Flow: Buyer → IT Dept → NRI
🌏 INDIA ₹ → $ 🏦 NRI A/C USD 1 Million / Year Cap
🌐 FEMA Repatriation of Sale Proceeds

Why Does Buying from an NRI Change Everything?

Purchasing a flat, plot, or commercial space in India is already a multi-step process. But when the seller is a Non-Resident Indian (NRI), the tax and compliance obligations change dramatically — for both parties.

The key difference: under a regular resident-to-resident deal, the buyer simply deducts 1% TDS above ₹50 lakh. With an NRI seller, the buyer must deduct TDS at significantly higher rates — on the entire sale consideration, with no minimum threshold — and file different returns. The NRI seller, meanwhile, faces capital gains tax, potential double taxation, and repatriation regulations under FEMA.

📋 Legal Framework at a Glance

Income Tax Act 2025 (effective 1 April 2026) — Section 393(2) governs TDS on NRI property sellers, replacing the earlier Section 195. Section 84 provides capital gains exemption (replaces Section 54). Buyer files Form 27Q (TDS return for non-residents). Post-Budget 2026, TDS deposited using buyer’s PAN instead of TAN.

Official Source: incometaxindia.gov.in — TDS on Purchase of Immovable Property


Who Qualifies as an NRI Under Indian Tax Law?

Under Section 6 of the Income Tax Act, an individual is a Non-Resident Indian (NRI) if they do not satisfy the resident conditions — broadly, anyone who has spent fewer than 182 days in India during the financial year.

⚠️ Critical for Buyers — Verify NRI Status Upfront

If a seller is an NRI but represents themselves as a resident, and you deduct TDS at only 1%, you can receive an assessee-in-default notice from the Income Tax Department, with interest and penalties on the shortfall. Always obtain a written declaration of residential status from the seller before any payment.


Obligations of the Buyer (Indian Resident)

The governing provision under the Income Tax Act 2025 is Section 393(2) [Table: Sl. No. 17] — equivalent to the earlier Section 195 of the 1961 Act. When you buy from an NRI, the full compliance burden falls on you.

TDS Rates — What to Deduct

Holding Period Gain Type Base TDS Rate Effective Rate (approx.)
More than 24 months LTCG 12.5% ~14.95% (max)
24 months or less STCG Slab rates Up to ~34.32%
No PAN furnished Higher Rate 20% or treaty rate 20% or more
✅ No Threshold — No Exceptions

Unlike the ₹50 lakh threshold for resident sellers, there is no minimum threshold when the seller is an NRI. TDS must be deducted on every rupee of consideration, regardless of the property value. As confirmed by the Income Tax Department (incometaxindia.gov.in): “If the seller is a non-resident, TDS is applicable under Section 195 [now Section 393(2)].”

Step-by-Step: Buyer’s Compliance Process

1
Obtain Seller’s Residential Status Declaration

Get a written declaration from the NRI seller confirming non-resident status, supported by passport copy, visa, and overseas address proof.

2
Obtain NRI’s PAN (Mandatory)

If the NRI does not furnish their Indian PAN, TDS is deducted at 20% or the applicable rate — whichever is higher — under Section 206AA.

3
Check for Lower Deduction Certificate (Form 13 / Section 197)

If the NRI holds a Lower Deduction Certificate, deduct TDS at the reduced rate shown on the certificate.

4
Deduct TDS on Every Payment

Deduct on each installment — advance, intermediate, and final. Budget 2026 (effective 1 Oct 2026): use your PAN for deposit; TAN is no longer required.

5
Deposit TDS — Challan ITNS 281

Deposit the deducted TDS within 7 days from end of the month of deduction (for March: by 30 April).

6
File Quarterly TDS Return — Form 27Q

File Form 27Q (NRI payment TDS return) within 31 days from the end of the quarter. Different from Form 26QB used for resident sellers.

7
Issue Form 16A to the NRI Seller

Generate and provide the TDS Certificate (Form 16A) from TRACES within 15 days of the TDS return due date.

📊 Worked Example 1

Mr. Arjun (Hyderabad) buys flat from Mr. Raj Mehta (NRI – USA)

Property held by NRI for 4 years → LTCG applies. Sale consideration: ₹1,20,00,000

Sale Consideration₹1,20,00,000
Base TDS Rate (LTCG – 12.5%)12.5%
Base TDS Amount₹15,00,000
Surcharge @ 15% (income > ₹1 Cr)₹2,25,000
Health & Education Cess @ 4%₹69,000
Total TDS to Deduct & Deposit₹17,94,000
Net Paid to NRI Seller₹1,02,06,000

Tax Obligations of the NRI Seller

As an NRI seller, you are taxed in India on the capital gains arising from the sale. The buyer deducts TDS from the gross consideration, but your actual tax liability is only on the net capital gain — meaning you are often entitled to a significant refund.

Holding PeriodClassificationTax Rate (FY 2025-26)
More than 24 monthsLTCG12.5% + surcharge + cess
24 months or lessSTCGApplicable slab rates + surcharge + cess
“TDS deducted by the buyer is not the NRI’s final tax — it’s a withholding. The NRI’s actual liability is on capital gains only, and any excess TDS can be claimed as a refund by filing an ITR in India.”
📊 Worked Example 2 — NRI Seller Tax vs TDS

Ms. Priya Sharma (NRI – UK) sells her Mumbai apartment

Bought 2018 @ ₹60 lakh. Sold 2025 @ ₹1,20,00,000. Held 7 years → LTCG.

Sale Consideration₹1,20,00,000
Cost of Acquisition (2018)₹60,00,000
Long-Term Capital Gain₹60,00,000
Tax on LTCG @ 12.5%₹7,50,000
Surcharge (15%) + Cess (4%)₹1,56,000
Actual Tax Liability₹9,06,000
TDS Already Deducted by Buyer₹17,94,000
Refund Claimable via ITR₹8,88,000 ✅
✅ Lower Deduction Certificate — Apply Before Sale

NRI sellers can apply in Form 13 under Section 197 at the Income Tax portal before the sale is concluded. The Assessing Officer evaluates the actual capital gain and issues a certificate for TDS at a lower or nil rate, which the seller shares with the buyer.


Capital Gains Exemptions Available to NRI Sellers

NRI sellers are entitled to the same exemptions as resident Indians under the Income Tax Act 2025:

Section (ITA 2025)Earlier SectionAsset SoldReinvestmentCap
Section 84Section 54Residential houseBuy/construct 1 house in India (1 yr before or 2 yrs after)₹10 crore
Section 84FSection 54FAny long-term asset (not house)Net consideration → new house in India₹10 crore
Section 54ECSection 54ECAny long-term propertyLTCG → NHAI/REC bonds within 6 months, 5-yr lock-in₹50 lakh
❌ Reinvestment Must Be in India

Exemptions under Section 84 / 84F require reinvestment in residential property located in India only. Investment in foreign property does not qualify. The ₹10 crore cap (introduced Finance Act 2023) applies equally to NRIs.

📊 Worked Example 3 — Section 84 Exemption

Mr. Vikram Nair (NRI – Singapore) reinvests LTCG to claim exemption

Sells Chennai flat (held 8 yrs) for ₹1.5 Cr. LTCG = ₹80 lakh. Buys Pune flat within 1 year for ₹85 lakh.

LTCG on sale of Chennai flat₹80,00,000
Amount reinvested in Pune flat₹85,00,000
Exemption under Section 84₹80,00,000 ✅
Taxable Capital Gain₹NIL 🎉

Note: New Pune flat must be held for at least 3 years; selling earlier revokes the exemption.


Repatriation of Sale Proceeds — FEMA Rules

RouteLimitConditions
NRO AccountUSD 1 million / financial yearAll taxes paid; Form 145 + Form 146 required
NRE AccountUp to 2 residential propertiesProperty purchased with inward foreign remittance / NRE funds
Inherited PropertyUSD 1 million / yearInheritance must be documented; FEMA declaration required
📑 Forms 145 & 146 (Earlier: 15CA & 15CB)

Under Income Tax Rules 2026, Form 15CA → Form 145 (self-declaration by NRI confirming taxes paid) and Form 15CB → Form 146 (CA’s certificate certifying tax and FEMA compliance). Your bank will not process the international wire transfer without both for remittances above ₹5 lakh.


Consequences of Non-Compliance

Failure to deduct or deposit TDS renders the buyer an assessee-in-default as per the Income Tax Department’s official guidance.

Non-Deduction Interest
1.5% pm
From date of deductibility to date of actual deduction
Non-Deposit Interest
1.5% pm
From date of deduction to actual deposit date
Penalty – Not Deducted
= TDS amt
Penalty equal to TDS not deducted (Section 271C)
Late Filing Penalty
₹200/day
Per day for late Form 27Q (Section 234E)
Non-Filing Penalty
₹10K–₹1L
Section 271H for non-filing / incorrect TDS statement
No TDS Certificate
₹500/day
Failure to issue Form 16A (Section 272A)

Buyer vs NRI Seller — Obligations at a Glance

Indian Resident Buyer
  • Deduct TDS at LTCG/STCG rate on entire consideration
  • No minimum threshold — applies on even ₹1
  • Deposit via Challan ITNS 281 (PAN after Oct 2026)
  • File Form 27Q quarterly TDS return
  • Issue Form 16A TDS certificate to NRI seller
  • Verify NRI status in writing before any payment
NRI Seller
  • Tax is on net capital gain, not gross sale price
  • Apply for Lower Deduction Certificate (Form 13)
  • Claim exemptions under Section 84 / 54EC
  • File ITR in India to claim TDS refund
  • Submit Form 145 + 146 for repatriation
  • Repatriation capped at USD 1 million/year (NRO)

Double Taxation Relief — DTAA Benefits

India has DTAAs with over 90 countries. NRI sellers taxed both in India and in their country of residence can claim relief under the applicable treaty to avoid double taxation.

💡 How DTAA Works in Practice

If Mr. Raj Mehta (NRI – USA) pays capital gains tax of ₹9 lakh in India, he may claim a foreign tax credit on his US federal return for the Indian tax paid. NRIs should provide a Tax Residency Certificate (TRC) from their country of residence to the buyer/bank to claim DTAA benefit.

📚 Official Sources & References 1. Income Tax Department — TDS on Purchase of Immovable Property (incometaxindia.gov.in)
2. Income Tax Department — TDS from Sum Paid to Buy Immovable Property
3. Income Tax Act 1961 — Section 195; replaced by Section 393(2) of Income Tax Act 2025 w.e.f. 1 April 2026
4. Income Tax Act 2025 — Section 84 (erstwhile Section 54); Section 393(1) & 393(2)
5. FEMA 1999 — RBI Master Directions on Remittance of Assets from NRO Accounts
6. Finance Act 2026 — TAN removal for NRI property TDS; Form renaming (15CA→145, 15CB→146)
7. Income Tax Rules 2026 — Rule 218 & 219 (TDS deadlines), Forms 141 & 27Q
Disclaimer: This article is for educational and informational purposes only. Tax laws are subject to change. Always consult a qualified Chartered Accountant or tax professional and verify current provisions at incometaxindia.gov.in.