Part DCA - Safe Harbour Rules for income referred to in clause (i) of sub-section (1) of section 9 chargeable to tax under the head (From Rule 10TI to Rule 10TIC)
Apportionment of offshore transfer income to Indian assets follows a prescribed formula and certification requirement. Income from the offshore transfer of a share or interest in a company or entity covered by section 9(1)(i) is apportioned to assets located in India by applying the prescribed formula, namely A x B/C. A is the transfer income computed under the Act as if the share or interest were located in India, while B and C represent the fair market value of Indian assets and all assets respectively, both determined under rule 11UB. If the required information is not furnished, the Assessing Officer may determine the income in a suitable manner.
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.
Apportionment of offshore transfer income to Indian assets follows a prescribed formula and certification requirement.
Income from the offshore transfer of a share or interest in a company or entity covered by section 9(1)(i) is apportioned to assets located in India by applying the prescribed formula, namely A x B/C. A is the transfer income computed under the Act as if the share or interest were located in India, while B and C represent the fair market value of Indian assets and all assets respectively, both determined under rule 11UB. If the required information is not furnished, the Assessing Officer may determine the income in a suitable manner.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 
Join Channel
TaxTMI 
