Chapter XIII - Determination of Tax in Special Cases
Section 211
Section 211: tax on non-resident sportsmen, sports associations and entertainers
Section 211 sets a flat 20% rate on specified categories of India-sourced income earned by non-citizen non-resident sportsmen, non-resident sports associations/institutions, and non-citizen non-resident entertainers.
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Need advice on Section 211?
This article is for general information. Refer to the Income-tax Act, 2025 as amended by the Finance Act, 2026 and the Taxation and Other Laws (Amendment) Act, 2026 for the official provisions. If you need professional advice for your situation, contact Bizeneed.
Statutory text
Bare law
(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:—
| Sl. No. | Income | Rate of income-tax payable |
|---|---|---|
| 1 | Income referred to in clause (a) or (b) or (c). | 20% |
| 2 | Total income as reduced by income referred to in clause (a) or (b) or (c). | Rates in force. |
(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.
Introduction
The 20% rate applies only to the income categories listed in Section 211; any remaining total income is taxed at the rates otherwise in force. No expenditure or allowance deduction is permitted when computing the specified income.
Key takeaways
20% on specified income
The section covers the listed Indian sports, sports-association and entertainment income; other income remains subject to rates in force.
Citizenship and residence conditions differ
A sportsman or entertainer must be both non-resident and not an Indian citizen; the association or institution category requires non-resident status.
No expense deduction
Expenditure and allowances cannot be deducted in computing the income covered by this section.
Return exception has two conditions
A Section 263(1) return is unnecessary only if total income consists solely of this specified income and tax has been deducted at source.
Who and what income this covers
The flat rate applies to total income that includes:
- For a sportsman (including an athlete) who is not a citizen of India and is a non-resident: income from participation in India in any game (other than a game whose winnings are taxed under section 194(1) Table Sl. No. 1) or sport; income from advertisement; or income from contributing articles about a game or sport in Indian newspapers, magazines or journals.
- For a non-resident sports association or institution: any amount guaranteed to be paid or payable in relation to a game (other than a game whose winnings are taxed under section 194(1) Table Sl. No. 1) or sport played in India.
- For an entertainer who is not a citizen of India and is a non-resident: income received or receivable from a performance in India.
The rate
Where these conditions are met, the aggregate tax payable is computed at:
| Income | Rate of income-tax payable |
|---|---|
| Income described above | 20% |
| Total income as reduced by that income | Rates in force |
No deductions, and return-filing exemption
No deduction for any expenditure or allowance is allowed under any provision of the Act when computing this income.
The assessee need not furnish a return of income under section 263(1) if the total income for the year consisted only of this income, and tax was deducted at source from it.
Step-by-step flow for applying Section 211
- 1
Who is earning the income?
A sportsman (including an athlete) or entertainer who is not a citizen of India and is a non-resident, or a non-resident sports association or institution.
- None of these: Section 211 does not apply.
- One of these: Go to the next step.
- 2
Is the income of a covered type?
Sportsman: participation in India in a game or sport, advertisement, or contribution of articles on games or sport to Indian newspapers, magazines or journals. Association: amounts guaranteed for a game or sport played in India. Entertainer: performance in India. Games whose winnings are taxed under Section 194(1) (Table Sl. No. 1) are excluded.
- No: Tax that income under the other provisions of the Act.
- Yes: Go to the next step.
- 3
Tax at 20% on the gross amount
No deduction for any expenditure or allowance is allowed under any provision of the Act (Section 211(2)). The rest of total income is taxed at the rates in force.
- 4
Is a return required?
- Only Section 211 income and TDS deducted: No return under Section 263(1) is required (Section 211(3)).
- Otherwise: File a return.
Practical checklist
Do
- Confirm the taxpayer is a covered non-resident sportsperson, sports association or entertainer and classify each Indian-source receipt.
- Check withholding before relying on any return-filing exception.
Avoid
- Claim ordinary expense deductions against covered income without checking the section.
Illustrative example
Worked example: a foreign cricketer playing a league in India
Hypothetical facts (illustration only, not a real taxpayer): Mr. Smith, a non-resident who is not an Indian citizen, receives ₹40,00,000 for playing in a cricket league in India and ₹10,00,000 for an advertisement. He spends ₹5,00,000 on travel and coaching. He has no other Indian income, and tax was deducted at source on both payments.
Covered income
Participation fee and advertisement income both fall in Section 211(1)(a): ₹40,00,000 + ₹10,00,000 = ₹50,00,000.
No deductions
The ₹5,00,000 of expenses cannot be deducted (Section 211(2)).
Tax
₹50,00,000 x 20% = ₹10,00,000.
Return
His total income consists only of Section 211 income and TDS was deducted, so no return under Section 263(1) is needed (Section 211(3)).
Outcome
- Tax under Section 211 is ₹10,00,000.
- Surcharge and cess, if applicable, are outside this illustration.
Glossary
- Sportsman
- Includes an athlete; must be a non-resident who is not a citizen of India.
- Entertainer
- A non-resident who is not a citizen of India and earns income from performance in India.
- Guaranteed amount
- An amount guaranteed to be paid or payable to a non-resident sports association or institution in relation to a game or sport played in India.
Frequently asked questions
What rate applies to a foreign sportsman's Indian match earnings?
20%, on income from participation in a game or sport in India, advertisement income, and income from articles about a game/sport published in Indian newspapers, magazines or journals.
Can expenses be deducted from this income?
No - Section 211(2) disallows any deduction for expenditure or allowance against this income.
Does a foreign sportsman need to file a return if only this income was earned?
No return under section 263(1) is required if the total income consisted only of this income and tax was deducted at source from it.
Need help applying this provision to your situation?
Get help with your non-resident sportsman/entertainer tax positionLast updated 10 October 2026