NRI Accounts in India:  A Legal Study of the Regulatory Framework and Compliance Mechanism

Abstract

This article critically examines the legal framework and compliance mechanisms governing Non-Resident Indian (NRI) accounts in India, with particular emphasis on the provisions of the Foreign Exchange Management Act (FEMA), 1999, and regulatory guidelines issued by the Reserve Bank of India (RBI). The article explores the classification of NRE, NRO, and FCNR accounts; their legal distinctions; taxation regimes; repatriation limits; and enforcement mechanisms. An empirical research methodology was adopted, involving the analysis of statutory instruments, circulars, and RBI master directions to assess practical challenges and compliance gaps. The paper also highlights complex intersections between domestic regulatory requirements and international reporting obligations like FATCA and CRS. It concludes by identifying the need for greater legal clarity and uniform enforcement practices across institutions to enhance transparency and ease of compliance for NRIs.

Keywords: NRI, Bank Accounts, FEMA, RBI, NRO, NRE, FCNR, FATCA, CRS Compliance, Taxation

Introduction

India’s Non-Resident Indian (NRI) banking regime is governed by a comprehensive legal framework to facilitate legitimate cross-border capital flows while ensuring foreign exchange control. According to the FEMA Regulation, the NRI has been defined as “A ‘Non-resident Indian’ (NRI) is a person resident outside India who is a citizen of India.”[1] NRIs may hold special accounts in India either in rupees or in foreign currency under the rules framed in the Foreign Exchange Management Act, 1999 (FEMA)[2], and regulated by the RBI. The regulatory framework permits three principal account types – the Non-Resident External Rupee Account (NRE), the Non-Resident Ordinary Rupee Account (NRO), and the Foreign Currency Non-Resident Bank Account (FCNR-B) – each with distinct features.[3] RBI issues Master Directions and Notifications, for example, FEMA Notification No. 5/2000 dated May 3, 2000, and periodic circulars that consolidate instructions on these accounts.[4]

Income Tax laws further differentiate NRI accounts[5] interest on NRE and FCNR deposits is tax-exempt in India, whereas NRO income is taxable.[6]

Definition and Classification of NRI Accounts

Similar to what NRI typically means, a “Person of Indian Origin (PIO)” is a citizen of another country, excluding Pakistan or Bangladesh, who has Indian heritage, or the spouse of such a person, and who satisfies any of the following criteria: (a) Was a citizen of India under the Constitution of India or the Citizenship Act, 1955; (b) Belonged to a territory that became part of India after August 15, 1947[7]; (c) Is a child, grandchild, or great-grandchild of such a person[8]; (d) Is a foreign-origin spouse of a citizen of India or of a person covered under the above clauses.[9]

Additionally, a PIO includes an Overseas Citizen of India (OCI) cardholder as defined under Section 7A of the Citizenship Act, 1955, provided they also reside outside India.[10]

In terms of a practical scenario, NRIs and PIOs, including Overseas Citizen of India cardholders, are eligible to open NRI-designated bank accounts. Under FEMA (Deposit) Regulations, 2000, only authorized banks can maintain deposits with persons outside India.[11]

The major NRI account categories are:

• NRE (Non-Resident External) Rupee Account: This is an Indian-rupee account maintained for NRIs/PIOs or erstwhile Overseas Corporate Bodies. An NRE account accepts funds remitted from abroad in foreign exchange, which are converted to Indian rupees on credit. The principal and interest in an NRE account are fully repatriable i.e., freely transferable abroad. The account holder, an NRI/PIO, may open NRE savings, current, recurring, or fixed deposit accounts.[12] Only NRI/PIO holders can open NRE accounts; joint accounts with residents are permitted only on ‘former or survivor’ basis.[13] Importantly, interest earned on NRE deposits is tax-free in India[14], making these accounts attractive for foreign income.[15]
• NRO (Non-Resident Ordinary) Rupee Account: This rupee account allows NRIs/PIOs to hold income and investments in India, for example, rent, dividends, local salaries, or proceeds from the sale of assets.[16] Funds in an NRO account originate from Indian-sourced income or transfers from other NRO accounts, and may include inward remittances. An NRO account may be opened by ‘any person resident outside India’, subject to FEMA restrictions on Pakistani/Bangladeshi nationals who need RBI permission.[17] It can be maintained in the form of savings, current, recurring or fixed deposits.[18] By default, NRO funds are ‘non-repatriable’ except under prescribed limits. Repatriation of NRO balances after taxation is allowed up to USD 1 million per financial year under FEMA (Remittance of Assets) Regulations, 2016.[19] Interest earned on NRO accounts is taxable in India, with tax deducted at source as per the taxation rules.
• FCNR (B) – Foreign Currency Non-Resident (Bank) Account: NRIs/PIOs and erstwhile OCBs may open fixed-term deposits in freely convertible foreign currencies under the FCNR(B) scheme.[20] These are term deposits in, say, USD, EUR, GBP, etc. Both principal and interest are fully ‘repatriable’ in foreign currency. Like NRE deposits, FCNR(B) interest is exempt from Indian income tax.[21] FCNR(B) accounts are typically fixed deposits (1–5 years) and cannot be used for rupee transactions. Only NRIs/PIOs can open FCNR accounts jointly with resident relatives is permissible.[22]

In summary, NRE and FCNR accounts are intended to park ‘foreign income’ in India, which is fully repatriable, tax-exempt in India, whereas NRO accounts are for holding ‘Indian-sourced rupee funds’ with limited repatriability, taxable. FEMA regulations (Deposit) specify exactly who may maintain each scheme: banks “may accept deposits under the NRE scheme… from a non-resident Indian or an overseas corporate body,” under FCNR-B, similarly from an NRI/OCB, and under NRO from “any person resident outside India”.[23] These definitions and schemes, along with eligibility such as requiring RBI approval for certain nationalities, are codified in FEMA Notification No. 5/2000 and subsequent RBI instructions.[24]

Regulatory Framework

The primary law is the Foreign Exchange Management Act, 1999 (FEMA), which replaced the old FERA (Foreign Exchange Regulation Act) to liberalize foreign exchange norms. Under FEMA, Section 6(1) and (2) generally prohibit “current account” transactions and allow limited exceptions by RBI; acceptance of foreign currency deposits falls under RBI’s rule-making powers.[25] In exercise of these powers, the RBI issued the FEMA (Deposit) Regulations, 2000 (Notification FEMA 5/2000, May 3, 2000). These regulations explicitly define NRI/PIO and the various account schemes such as NRE, NRO, FCNR-B, NRNR, etc., and set out the terms of deposits.[26] For example, FEMA Deposit Reg. 5(1)(i)-(iii) permits an Authorized Dealer (bank) to accept deposits under the NRE, FCNR-B, and NRO schemes from eligible non-residents.[27]

RBI supplements FEMA by issuing Notifications and Master Directions. For instance, RBI’s FEMA Notification No.5/2000-RB (Deposit Regs.) contains definitions of NRI, PIO, NRE, NRO, etc., and detailed annexures or the “Schedules” governing allowable credits/debits and operations for each account type. RBI also issues Master Circulars that consolidate all instructions on NRI accounts, for instance, the “Master Circular – Non-Resident Ordinary (NRO) Rupee Account”.[28] These circulars reiterate FEMA provisions and RBI’s own rulings, covering account opening, permissible transactions, and special cases like accounts of foreign nationals in India, changes of residential status, loans against deposits, etc.

Key RBI Guidelines:

Several RBI master directions and circulars directly address NRI accounts:

• Permissible Transactions: The RBI specifies what credits/debits each account may have. For example, an NRE account may be credited with inward remittances, interest, and certain legitimate incomes like overseas dividends[29], and debited only for local rupee payments or remittances abroad. An NRO account can receive inward remittances from abroad, Indian income (rent, etc.), and transfers from other NROs, but can only be debited for local payments, NRE transfers, or repatriations up to $1M.[30] These rules are drawn from FEMA Deposit Schedules and RBI circulars.
• Joint Accounts and Nomination: NRIs/PIOs may hold NRE/FCNR accounts jointly with other NRIs or with a resident relative on ‘former-or-survivor’ basis.[31] Power-of-attorney operations are allowed; withdrawals for permissible purposes, under conditions. RBI allows nomination in NRI accounts.[32]
• Change of Status: When an account holder’s residential status changes, for example, NRI returns to India, RBI mandates converting his NRE/FCNR balances to an RFC (Resident Foreign Currency) account or resident rupee account immediately. If a resident becomes an NRI, his existing rupee accounts are redesignated NRO.[33] These provisions ensure accounts reflect the correct legal status of the holder.
• Loans and Advances: RBI permits banks to grant rupee loans against NRE/FCNR deposits (for bona fide Indian purposes) under specific guidelines.[34] Loans cannot be used to evade restrictions (no relending, no agricultural/real estate out-of-scope). Banks may also extend loans abroad against Indian deposits as security (subject to FEMA loan rules).
• RBI Master Directions: In 2016 and thereafter, RBI issued consolidated Master Directions on various banking operations (KYC, transfer of funds, foreign exchange, etc.) that impact NRIs. For example, the RBI Master Direction – KYC Norms (2016) requires banks to adhere to stringent due diligence on non-resident customers, including verification of overseas address, valid Indian identification (passport/PAN), and risk profiling.[35] The RBI Master Direction – Reporting (FATCA/CRS) enjoins all banks to identify and report NRI deposit accounts as per Income Tax Rules 114F/114G/114H.[36] (See Compliance section below.) RBI’s regulations on Liberalised Remittance Scheme (LRS) and foreign investments do not directly limit NRI accounts but do impose ceilings on residents’ remittances/gifts (see also FEMA LRS rules for resident gifting to NRIs).

In essence, the regulatory framework blends FEMA’s statutory provisions with detailed RBI circulars and master directions. Official sources like FEMA Deposit Regs. and RBI master circulars are the primary law for NRI accounts.[37] Banks and NRIs must follow these to ensure that deposits and transactions are “bona fide” under FEMA and RBI guidelines.

Taxation and Repatriation Rules

Indian tax law accords favorable treatment to certain NRI account incomes. Under the Income Tax Act, interest earned on NRE and FCNR(B) deposits is fully exempt from tax in India. Specifically, section 10(4)(ii) of the IT Act exempts interest on NRE accounts[38], and section 10(15)(iv)(fa) exempts interest on FCNR deposits[39] as long as the depositor is Non-Resident or Resident but Not Ordinarily Resident.[40] Thus, NRI account holders pay no Indian tax on earnings in NRE/FCNR accounts. However, such interest may be taxable in the NRI’s country of residence.

By contrast, interest on NRO accounts is taxable in India. NRO interest is subject to withholding tax at 30% (plus cess) at the time of credit or payment. The NRI must include this income in Indian tax returns if applicable. Banks collect TDS on NRO interest. (Note: There used to be a question whether NRE interest would ever be taxed in India – by law it is not, though some older representations proposed taxing it.[41] As of now, NRE and FCNR interest remain exempt.)

Repatriation of Funds

The ability to send money abroad differs by account type:

• NRE/FCNR: Both the principal and interest in NRE and FCNR accounts are fully and freely repatriable in foreign exchange. An NRI can remit any amount from NRE/FCNR balances abroad through banking channels without RBI permission. (Of course, such transfers must comply with the Income Tax Act’s provisions – e.g. if funds were received as certain gifts, threshold filing requirements may apply.)
• NRO: NRO accounts are primarily non-repatriable (rupee accounts). However, FEMA (Remittance of Assets) Regulations, 2016 (Reg.8) allow NRIs/PIOs to remit up to USD 1 million per financial year (April–March) out of balances held in NRO accounts, after fulfilling tax obligations.[42] This USD 1 million cap applies to the total of eligible assets, including NRO funds, sale proceeds of assets, etc., and is subject to (a) payment of applicable taxes on such funds; and (b) submission of prescribed declarations. In practice, for remitting NRO funds, banks require a chartered accountant’s certificate (Form 15CB) confirming that tax has been paid on the amount, and the taxpayer’s declaration on Form 15CA (to the Income Tax Department). Beyond USD 1 million, RBI approval is needed for the remittance.
• Other conditions: In certain cases (e.g. premature withdrawal of fixed deposits or loans against deposits), RBI has specified lock-in periods or conditions to prevent channel misuse. For instance, an NRI must keep an NRO term deposit for at least one year to repatriate it, and banks must ensure funds remitted were originally earned/incurred legally in India. Gifts or loans in rupees from residents to NRIs are allowed up to LRS limits (currently $250,000) only via the LRS i.e., residents remitting/crediting to NRO accounts under LRS rules.

Repatriation of Assets

Rules also address NRI investments. For example, sale proceeds of residential property received in India (credited to NRO) can be repatriated only up to USD 1 million per year, and any further amounts would need special approval.[43] Importantly, FEMA now treats LRS investments by residents to NRO accounts as resident-to-resident transactions (no contravention), so funds within LRS limits can be transferred to relatives’ NRE/NRO accounts as gift without RBI permission.

In summary, NRE and FCNR funds enjoy unfettered remittance rights, while NRO repatriation is limited and conditional. Tax obligations also vary: interest on NRE/FCNR is exempt[44], while NRO income is taxed. NRI account holders must comply with Income Tax Act provisions (filing returns, TDS, etc.) when repatriating funds.

Compliance Mechanisms and Documentation

KYC and Account Opening

Banks must follow RBI’s KYC (Know Your Customer) guidelines when opening NRI accounts. Required documents typically include the NRI’s passport (and Indian visa, if applicable), proof of overseas address (utility bill, bank statement from abroad, etc.), proof of Indian address (if any), PAN card (Permanent Account Number) or Form 60/61, and a recent photograph. Power of attorney holders must provide a notarized POA. The RBI’s Master Direction on KYC (2016) and periodic updates mandate that non-resident customers are properly identified and risk-rated.[45] Banks also collect FATCA/CRS self-certifications (see below). Failure to maintain updated KYC can lead banks to freeze NRI accounts.

FATCA and CRS

In the global tax compliance regime, Indian banks must identify NRI accounts subject to the U.S. FATCA (Foreign Account Tax Compliance Act) and the OECD’s CRS (Common Reporting Standard). Under RBI’s KYC Master Direction, banks are required to follow Income Tax Rules 114F/114G/114H, which implement FATCA/CRS in India.[46] This means:

• Due diligence: Banks must determine if an NRI account holder is a U.S. person (FATCA) or a tax resident of other reportable jurisdictions (CRS). NRIs must fill FATCA/CRS declaration forms indicating their country of tax residence and FATCA classification.
• Reporting: If an NRI account is identified as reportable, the bank must report the account details and balance to the Indian tax authorities (CBDT) via Form 61B. These reports are then shared with foreign tax agencies under inter-governmental agreements. RBI’s guidelines instruct banks to register on the Income-Tax e-filing portal as Reporting Financial Institutions and submit annual FATCA/CRS returns.[47]
• Compliance checks: RBI also expects banks to put in place IT systems and audits to ensure ongoing FATCA/CRS compliance.

Form 15CA/CB

For repatriation of NRO funds (and certain NRE transfers if taxable), banks require Form 15CA/CB filings. Under Income Tax Rule 37, any remittance abroad must be declared on Form 15CA; if tax is applicable (as in NRO earnings), a chartered accountant’s certificate (Form 15CB) is needed.[48] These certifications ensure that the bank (payer) has assessed and deducted the correct tax before remittance. This process is mandated by the Income Tax Department, and banks typically refuse outward transfers without them. (Note: Sections 196D/195 of the Income Tax Act also govern non-resident taxation.)

Other Documentation

Additional compliance includes:

• FEMA Reporting: Certain transactions (e.g. large remittances or investments) must be reported to RBI via AD regulatory returns (e.g. Forms A2, OIA for overseas remittances/investments).
• Miscellaneous Disclosures: NRIs must comply with Indian tax laws on global income (if RNOR) and disclose foreign assets in their Indian tax returns (Schedule FA).
• Penalties for Lapses: Under KYC/AML laws (PMLA Act, 2002), wilful misreporting or non-cooperation can result in STR filings by banks, with penalties for banks. For instance, FATCA non-compliance may attract fines.[49]

In effect, opening or operating an NRI account involves multilayered compliance: RBI/FEMA norms, income tax/formalities, and international reporting (FATCA/CRS). Each NRI account holder must keep documentation (visas, passports, address proofs) up to date, submit required forms for remittances, and disclose tax information truthfully. Banks, in turn, rely on RBI’s consolidated KYC/FATCA/CRS guidelines[50] to vet NRI customers and report as needed.

Enforcement and Legal Remedies

FEMA Enforcement

Violation of FEMA provisions related to NRI accounts (or any foreign exchange transaction) is a punishable offense under FEMA. FEMA treats contraventions as civil violations (unlike penal offenses under old FERA). Under Section 13 of FEMA, any person (including NRIs or banks) contravening FEMA regulations is liable to a penalty of up to three times the amount involved in the contravention, or ₹2 lakh if the amount is not quantifiable.[51] If the contravention is continuing, an additional penalty of up to ₹5,000 per day may be imposed.[52] For example, converting an NRE account to NRO account without following RBI rules, or remitting funds without following RBI directives, would attract FEMA penalties.

In more serious cases such as acquiring foreign assets in violation of FEMA thresholds, Sections 13(1A)–(1C) envisage confiscation of illegal gains and even criminal prosecution, imprisonment up to 5 years.[53] For instance, a failure to repatriate sale proceeds of property beyond permitted limits can lead to attaching assets and prosecution. The Adjudicating Authority (usually RBI or designated officials) determines penalties after giving notice. FEMA also allows compounding of offences (Section 15) – i.e., the violator can voluntarily come forward and pay a fine to settle a contravention, which is often used to regularize genuine mistakes in NRI remittance, subject to RBI approval and compounding fees.[54]

Role of Enforcement Directorate (ED)

The Directorate of Enforcement (under the Department of Revenue) investigates serious FEMA violations (as it does for money laundering or foreign exchange fraud). If RBI refers a case to ED, ED can attach properties under Section 37A of FEMA.[55] In practice, RBI’s foreign exchange department handles routine FEMA matters for authorized persons, and defaulters first go through adjudication and compounding. Appeals against adjudicating authority orders lie to the special FEMA appellate tribunal (which has now been replaced by the Finance Ministry’s appellate authority), and thereafter to High Courts.

Bank Liability

Authorized banks are themselves subject to FEMA penalties for non-compliance (e.g. if a bank allows an unauthorized transaction, or fails to repatriate funds as directed). RBI may inspect banks for FEMA compliance and impose penalties for procedural lapses (e.g. failure to report suspicious transactions from NRI accounts). Civil proceedings for FEMA contraventions are typically handled like debt recovery – civil courts can imprison defaulters for civil penalty defaults (subject to FEMA’s procedural safeguards).[56]

Legal Remedies

An NRI or bank aggrieved by an RBI adjudication has statutory appeal rights. After 2015, the FEMA Appellate Tribunal was merged into the Special Court (PMLA), and appeals now lie to the High Court. In addition, remedies under civil law (like injunctions to prevent illegal freezing of accounts) or even Writ petitions (fundamental rights grounds) may be available, though courts generally defer to RBI’s regulation of foreign exchange.

In essence, FEMA’s enforcement framework is strict; contraventions attract heavy civil penalties[57], and RBI has wide powers (inspection, attach, recovery) to ensure compliance. NRI account holders and banks must therefore adhere closely to FEMA and RBI rules, as deviations can lead to significant fines or legal action.

Challenges in Implementation and Legal Interpretation

While the NRI account framework is well-defined, practical and interpretational challenges arise:

• Residential Status Ambiguities: Determining an individual’s residential status (NRI, RNOR, etc.) can be complex. The Income Tax Act’s residency rules (e.g. 182-day rule) do not always align perfectly with FEMA’s notion of “resident”rbi.org.in. Banks often rely on self-declaration and visa stamps, but discrepancies (for example, an NRI who spends many days in India unexpectedly) can trigger reclassification of accounts. The treatment of NRIs who have become Resident but are still managing foreign-income accounts often confuses customers and banks.
• NRI Definitions (PIO vs OCI vs NRI): Legal definitions of PIO/OCI have evolved (the PIO card scheme has been merged into OCI cards). FEMA still recognizes “person of Indian origin,” which may cause uncertainty for certain foreign citizens of Indian descent. The RBI FAQ (2025) recognizes OCI cardholders as PIO-equivalent when resident abroad[58], but some banks may misinterpret documentation requirements.
• Compliance Complexity: The multilayered compliance (FEMA, RBI, Tax, FATCA/CRS) is burdensome. Smaller banks or NRIs may struggle with FATCA/CRS due diligence, leading to account closures or extra documentation requests. Errors in Form 61B reporting (by banks) or misunderstanding of FATCA status (by NRIs) can have reputational consequences.
• Tax vs FEMA Dichotomy: An NRI might be tax-resident in another country, pay taxes there, yet enjoy tax-free NRE income in India.[59] Coordinating double taxation relief under DTAAs can be tricky, especially if NRI status changes mid-year. Also, an NRI’s foreign income if undisclosed abroad might cause issues under anti-tax avoidance laws, complicating the repatriation of NRE funds.
• Operational Hurdles: In practice, even though NRE and FCNR funds are fully repatriable, banks often perform their own checks. Some banks cap the number of NRE transfers or demand advance notice for large remittances. Converting an NRE account to a resident account upon return, while mandated[60], may be delayed due to paperwork. Deadlines, for instance, repatriating within 60 days, can be overlooked.[61]
• Regulatory Updates: FEMA/ RBI guidelines on NRI matters have been updated (e.g. 2020, 2021) and scattered across circulars. Banks must continuously align with new norms (like updated KYC/V-CIP rules, or changes in permissible credits). Lack of awareness about recent changes (for example, 2016 compounding rules allowing wider remittance from NRO) can lead to unintentional non-compliance.

Despite these challenges, Indian regulators and courts have largely upheld the regime’s validity. Any ambiguities typically require referring back to the FEMA text or RBI notifications. For example, disputes on what constitutes “bonafide rupee transactions” which is permissible in NRO accounts are resolved by FEMA clarifications. Periodic FAQs by RBI such as the January 2025 one help clarify grey areas, for example, bank accounts for Pakistani nationals.[62] Still, legal practitioners often advise NRIs to maintain meticulous records and seek expert guidance before transferring large sums to mitigate interpretation risks.

Conclusion

India’s legal framework for NRI bank accounts strives to balance liberal capital flows with regulatory oversight. FEMA and RBI rules define exactly who can hold NRE, NRO, and FCNR accounts, what transactions each can undertake, and how funds may be repatriated. The regime complements favorable tax provisions (tax-exempt NRE/FCNR interest) with strict compliance demands like KYC checks, reporting, and limits on repatriation. RBI circulars and master directions provide granular instructions on account operations, loans, etc., while the Income Tax Act governs the tax dimension of account incomes and remittances.[63]

For NRIs and bankers, this means that opening and using an NRI account is subject to multiple legal safeguards; adherence to FEMA statutes, RBI guidelines, and Indian tax rules. Violations trigger civil penalties or even prosecution under FEMA.[64] The compliance framework also now extends globally (FATCA/CRS reporting). Thus, while the structure is comprehensive and generally facilitates remittances, both account holders and banks must navigate detailed procedures and stay updated on regulatory changes. In practice, clarity in documentation, cautious interpretation of “repatriability” rules, and timely coordination with tax compliance (forms 15CA/CB, FATCA/CRS filings) are essential. Overall, the NRI account system in India is robustly regulated by law, ensuring transparency of foreign funds while continuing to attract non-resident deposits through competitive interest rates and repatriability features. The legal mechanisms for enforcement and remedy ensure that FEMA’s aims and managing foreign exchange are met, even as India encourages its global diaspora to engage with the Indian banking system.[65]

Reference(S):

[1] Foreign Exchange Management (Debt Instruments) Regulations, 2019, § 2(p), G.S.R. 796(E), Gazette of India, Oct. 17, 2019 (India).

[2] Rules of Foreign Exchange Management Act, 1999, No. 42, Acts of Parliament, 1999 (India).

[3] ICICI Bank, Decoding NRE, NRO, and FCNR Accounts for Non-Resident Indians, https://www.icicibank.com/nri-banking/nriedge/nri-articles/decoding-nre-nro-and-fcnr-accounts-for-non-resident-indians (last visited July 1, 2025).

[4] Reserve Bank of India (RBI), Notification No. 5(R)/2019-RB, https://rbidocs.rbi.org.in/rdocs/notification/PDFs/NOTINO5(R)DE2833D3DFA8415BA5B586CFA3D4A946.PDF (last visited July 1, 2025).

[5] ClearTax, Income Tax for NRIs, https://cleartax.in/s/income-tax-for-nri (last visited July 1, 2025).

[6] id.

[7] Citizenship Act, 1955, § 7A(1)(a)(iii), No. 57, Acts of Parliament, 1955 (India).

[8] Citizenship Act, 1955, § 7A(1)(a)(iv), No. 57, Acts of Parliament, 1955 (India).

[9] Citizenship Act, 1955, § 7A(1)(d), No. 57, Acts of Parliament, 1955 (India).

[10] Citizenship Act, 1955, § 7A, No. 57, Acts of Parliament, 1955 (India).

[11] Foreign Exchange Management (Deposit) Regulations, 2000, FEMA Notification No. 5/2000-RB (India).

[12] Reserve Bank of India (RBI), FAQs on NRI Accounts, https://www.rbi.org.in/commonman/English/scripts/FAQs.aspx?Id=3 (last visited July 2, 2025).

[13] id.

[14] FEMA Online, Levying of Income Tax on Interest Earned on NRE/FCNR Accounts of NRIs, https://femaonline.com/cms/levying_of_income_tax_on_interest_earned_on_nre_fcnr_accounts_of_nris (last visited July 2, 2025).

[15] id.

[16] supra note 12.

[17] id.

[18] id.

[19] Foreign Exchange Management (Remittance of Assets) Regulations, 2016, Reg. 4(2), FEMA 13(R)/2016-RB (India).

[20] supra note 12.

[21] supra note 14.

[22] id.

[23] supra note 12.

[24] Foreign Exchange Management (Deposit) Regulations, 2000, FEMA Notification No. 5/2000-RB (India) and subsequent RBI instructions.

[25] Foreign Exchange Management Act, 1999, §§ 6(1)–(2), No. 42, Acts of Parliament, 1999 (India).

[26] supra note 12.

[27] Foreign Exchange Management (Deposit) Regulations, 2000, Reg. 5(1)(i)–(iii), FEMA Notification No. 5/2000-RB (India).

[28] supra note 12.

[29] id.

[30] supra note 19.

[31] ICICI Bank, Holding NRI Joint Accounts: All You Need to Know, https://www.icicibank.com/nri-banking/nriedge/nri-articles/holding-nri-joint-accounts-all-you-need-to-know (last visited July 3, 2025).

[32] Foreign Exchange Management (Deposit) Regulations, 2000, Sch. I para. 3 and [35] L427–435 (India).

[33] supra note 12.

[34] id.

[35] id.

[36] Income-tax Rules, 1962, rr. 114F–114H (India).

[37] supra note 12.

[38] Income-tax Act, 1961, § 10(4)(ii), No. 43, Acts of Parliament, 1961 (India).

[39] Income-tax Act, 1961, § 10(15)(iv)(fa), No. 43, Acts of Parliament, 1961 (India).

[40] supra note 14.

[41] id.

[42] Foreign Exchange Management (Remittance of Assets) Regulations, 2016, Reg. 8, FEMA 13(R)/2016-RB (India).

[43] supra note 12.

[44] supra note 14.

[45] supra note 12.

[46] supra note 36.

[47] supra note 12.

[48] Income-tax Rules, 1962, r. 37 (India).

[49] Prevention of Money Laundering Act, 2002, No. 15, Acts of Parliament, 2003 (India).

[50] supra note 12.

[51] Foreign Exchange Management Act, 1999, § 13, No. 42, Acts of Parliament, 1999 (India).

[52] id.

[53] Foreign Exchange Management Act, 1999, §§ 13(1A)–(1C), No. 42, Acts of Parliament, 1999 (India).

[54] Foreign Exchange Management Act, 1999, § 15, No. 42, Acts of Parliament, 1999 (India).

[55] Foreign Exchange Management Act, 1999, § 37A, No. 42, Acts of Parliament, 1999 (India).

[56] Foreign Exchange Management Act, 1999, No. 42, Acts of Parliament, 1999 (India).

[57] id.

[58] supra note 12.

[59] supra note 14.

[60] supra note 12.

[61] id.

[62] id.

[63] supra note 56.

[64] id.

[65] id.