Bahrain NRIs: The India-Side Changes You Missed in 2024-26

The India-Bahrain DTAA caps interest at 10% and is untouched by the 2024-26 changes. Your treaty rates are intact. What did change is almost everything around them.

**Section 148 reassessment.** Post Finance Act 2024, the time limit to reopen your Indian ITR is 3 years (5 years if escaped income is above ₹50 lakh). The old 10-year window is gone. AY 2018-19 and older are now time-barred for most NRIs.

**Section 151A faceless mandate.** The Telangana High Court (2024) plus the Supreme Court SLP dismissal (July 2025) confirmed that Section 148 notices issued directly by a Jurisdictional AO — bypassing the faceless scheme — are void. If you got one as a Bahrain NRI, check whether it was NFAC-issued before you reply.

**Budget 2024 capital gains.** LTCG on Indian property is now a flat 12.5% without indexation for NRIs. No carve-out. For long-held properties this can mean more effective tax despite the lower rate.

**Black Money Act safe harbour.** CBDT's September 2025 instruction raised the small-asset safe harbour from ₹5 lakh to ₹20 lakh for movable foreign assets. Useful if you're thinking of moving back to India.

Nothing in the 2024-26 India-side changes touches your core treaty rates. Bahrain NRIs continue to pay 10% on interest (vs 30% default) and 10% on dividends (vs 20% default). Equity capital gains are still source-taxed at 12.5%.

For the typical Bahrain-based Indian with NRO FDs and some Indian mutual fund holdings, the annual treaty recovery is unchanged. File Form 10F, attach a TRC from the Bahrain National Bureau for Revenue, claim treaty rates in the ITR. That's the repeatable saving and it still works.

Bahrain's National Bureau for Revenue started issuing TRCs regularly in 2022. The application is through the NBR online portal and takes about 3 weeks. Once you have it, Form 10F on the Indian e-filing portal is a 10-minute job.

If you got a Section 148 reassessment notice before September 2024, the Telangana HC / Supreme Court faceless-mandate ruling probably invalidates it — check who issued it before you reply. And if you're selling Indian property, Form 13 Section 197 before closing is the single biggest cash-flow saver in the playbook.