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of <h1>Section 9 defines incomes treated as accruing or arising in India, including business connection and attribution rules</h1> Section 9 deems specified incomes to accrue or arise in India, including amounts derived from a business connection, property, assets or capital transfers situate in India; salaries earned in India; dividends from Indian companies; interest, royalties and fees for technical services paid by Indian residents or where the use/benefit occurs in India; and certain payments from residents to non-residents. 'Business connection' includes activities by agents or significant economic presence (digital/transactional links), with income attributable to Indian operations taxed accordingly. Exceptions limit taxation for isolated activities (e.g., purchase for export, news collection, certain film shootings) and pensions payable outside India in prescribed circumstances; detailed attribution rules apply to transfers of foreign company shares deriving value from Indian assets.
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