Income deemed to accrue in India: territorial sourcing rules classify various receipts as Indian-sourced for tax purposes. Income is deemed to accrue in India if it arises through a business connection, property, asset or source in India, or by transfer of a capital asset situated in India. Specified categories treated as Indian-sourced include employment income linked to Indian service, dividends from domestic companies paid abroad, insurance premiums covering Indian risks, interest, royalties, technical service fees and transportation charges connected to India. For businesses with mixed operations only Indian-attributable income is deemed accruing; exceptions exclude certain export-related and exclusively foreign-source receipts. Nonresident share transfer income may be apportioned to India by a fair-value formula.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Income deemed to accrue in India: territorial sourcing rules classify various receipts as Indian-sourced for tax purposes.
Income is deemed to accrue in India if it arises through a business connection, property, asset or source in India, or by transfer of a capital asset situated in India. Specified categories treated as Indian-sourced include employment income linked to Indian service, dividends from domestic companies paid abroad, insurance premiums covering Indian risks, interest, royalties, technical service fees and transportation charges connected to India. For businesses with mixed operations only Indian-attributable income is deemed accruing; exceptions exclude certain export-related and exclusively foreign-source receipts. Nonresident share transfer income may be apportioned to India by a fair-value formula.
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