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No, OCI cardholders are treated as foreign citizens for tax purposes. Their tax liability is decided entirely based on their residential status under the Income Tax Act (182/120-day stay rules), not the OCI status.
Residential status for OCI holders is the same as everyone:
Only income sourced in India, such as rent, dividends, capital gains on Indian assets, and business profits, is taxable for non-resident OCI holders. Foreign income is not subject to taxation in India.
If the OCI holder becomes an ROR (Resident and Ordinarily Resident), their global income will be taxable. If they get the RNOR status (Resident but not Ordinarily Resident), their Indian income, as well as income received in India, will be subject to taxation.
Yes, OCIs need to file an ITR (Income Tax Return) in India if they have taxable income in India.