Deemed situs of foreign shares treats overseas shares as situated in India when their value derives substantially from Indian assets. Section 9 is amended to clarify that 'through' includes 'by means of', and that foreign shares are deemed situated in India when they derive substantially their value from Indian assets. The transfer of rights includes rights to use computer software (including licences) irrespective of transfer medium. 'Royalty' covers consideration for rights or information regardless of possession, use, or location, and 'process' includes transmission by satellite, cable, optic fibre or similar technologies. The clarifications have retrospective effect to the specified commencements.
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Provisions expressly mentioned in the judgment/order text.
Deemed situs of foreign shares treats overseas shares as situated in India when their value derives substantially from Indian assets.
Section 9 is amended to clarify that "through" includes "by means of", and that foreign shares are deemed situated in India when they derive substantially their value from Indian assets. The transfer of rights includes rights to use computer software (including licences) irrespective of transfer medium. "Royalty" covers consideration for rights or information regardless of possession, use, or location, and "process" includes transmission by satellite, cable, optic fibre or similar technologies. The clarifications have retrospective effect to the specified commencements.
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