Deemed situs of foreign shares: shares deriving value from Indian assets are treated as situated in India under tax law. Amendments to section 9(1) clarify that 'through' includes 'by means of', 'in consequence of' or 'by reason of'; foreign shares or interests whose value derives substantially from assets in India are deemed situated in India; transfer includes rights to use computer software including licences; royalty covers consideration for rights, property or information regardless of payer possession, use, or location; and 'process' includes transmission by satellite, cable, optic fibre or similar technology.
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.
Deemed situs of foreign shares: shares deriving value from Indian assets are treated as situated in India under tax law.
Amendments to section 9(1) clarify that "through" includes "by means of", "in consequence of" or "by reason of"; foreign shares or interests whose value derives substantially from assets in India are deemed situated in India; transfer includes rights to use computer software including licences; royalty covers consideration for rights, property or information regardless of payer possession, use, or location; and "process" includes transmission by satellite, cable, optic fibre or similar technology.
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