Section 115BBA and Section 115BBB: Tax on Non-Resident Sportsmen and Historical Mutual Fund Provision

Section 115BBA of the Income-tax Act, 1961 dealt with the special tax treatment of specified income of non-resident sportsmen, sports associations and certain non-resident entertainers. From 1 April 2026, the corresponding provision is Section 211 of the Income-tax Act, 2025. Section 115BBB, by contrast, was already a historical provision because its special 10% rule did not apply to relevant unit income arising after 31 March 2003.

Updated: 28 September 2026

Section 115BBA at a glance

Meaning and scope of the special rule

The provision is a special-rate rule for particular India-linked income earned by specified non-residents. Under the current Section 211 of the Income-tax Act, 2025, the covered income of the sportsman, sports association or entertainer is taxed at 20%. Any remaining total income is taxed at the rates otherwise in force.

For a non-resident sportsman, the rule covers income received or receivable from participation in India in a qualifying game or sport, from advertisements, and from contribution of articles relating to a game or sport in India to newspapers, magazines or journals. For a non-resident sports association or institution, it covers qualifying guaranteed payments connected with a game or sport played in India. It also covers performance income of a non-resident entertainer who is not an Indian citizen.

No deduction for expenditure or allowance

The special regime taxes the specified income without allowing a deduction for expenditure or allowance against that income. This is an important feature of both old Section 115BBA and current Section 211.

Return filing relaxation

Under current Section 211, a return is not required under the general return-filing provision where the assessee's total income consists only of the income covered by Section 211 and the tax deductible at source under the applicable TDS provisions has been deducted from that income. The statutory conditions should be checked for the relevant tax year before relying on this relaxation.

TDS on payments to non-resident sportsmen, associations and entertainers

Under the Income-tax Act, 2025, Section 393(2), Table item 1 requires tax deduction at source at 20% on income referred to in Section 211 when paid or credited to the specified non-resident sportsman, entertainer, sports association or institution. Under the former Income-tax Act, 1961, the corresponding TDS provision was Section 194E, also at 20%.

Section 115BBB: historical provision for open-ended equity-oriented funds

Section 115BBB remains relevant mainly for historical research, old assessments and understanding the evolution of the taxation of mutual fund income. It should not be presented as a current 10% tax regime for modern mutual fund income.

Transition from the Income-tax Act, 1961 to the Income-tax Act, 2025

Official references

Practical takeaway

For current tax years beginning on or after 1 April 2026, readers researching the old Section 115BBA should use Section 211 of the Income-tax Act, 2025 together with the applicable TDS provisions in Section 393. The 20% special rate continues for the specified income. Section 115BBB should be treated as a historical provision rather than a current mutual fund tax rate.