How are foreign retirement and pension incomes taxed in India?

Foreign retirement and pension incomes received by resident Indians are taxable in India under Section 5 of the Income Tax Act. However, any tax deducted in the source country can be claimed as FTC under Section 90/90A. If such income is taxed in India at special rates under Section 115H, the benefit of FTC under Section 90/90A is not available. For non-residents, only pension income sourced in India is taxable under Section 115B at a special rate of 20%. The Karnataka High Court in DIT v. Divya C. Bhatnagar [2022] held that foreign pension credited to an NRO account is deemed to accrue in India and taxable for non-residents.