To get certainty on tax position, a non-resident may consider seeking an advance ruling/private tax ruling.
The Authority for Advance Rulings (AAR) is an independent quasi-judicial body which issues advance rulings on income-tax matters. AAR rulings are binding on both the applicant and revenue authorities unless there is a change in law or facts.
Benefits:
Upfront resolution of questions related to tax liability
Avoid uncertainty and protracted litigation with revenue authorities
Lower time cost vis-à-vis normal dispute resolution process
Currently there is a lot of pendency in the AAR due to non-functioning in the past. Hence the option may require to be evaluated from a timing perspective