Residence and establishment criteria expanded to include entities established or registered in notified territories; sourcing phrase removed. The amendment inserts that an arrangement 'is established or incorporated or registered in a country or a specified territory notified by the Central Government,' extending applicability to entities established, incorporated, or registered in notified jurisdictions, and omits the phrase linking attribution to income 'from India,' thereby shifting emphasis from the prior source-oriented wording to establishment/registration and notified-territory nexus.
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.
Residence and establishment criteria expanded to include entities established or registered in notified territories; sourcing phrase removed.
The amendment inserts that an arrangement "is established or incorporated or registered in a country or a specified territory notified by the Central Government," extending applicability to entities established, incorporated, or registered in notified jurisdictions, and omits the phrase linking attribution to income "from India," thereby shifting emphasis from the prior source-oriented wording to establishment/registration and notified-territory nexus.
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