Chapter XII-DA - SPECIAL PROVISIONS RELATING TO TAX ON DISTRIBUTED INCOME OF DOMESTIC COMPANY FOR BUY-BACK OF SHARES (From Section 115QA to Section 115QC)
Part C - Procedure for filing of return in respect of fringe benefits, assessment and payment of tax in respect thereof (From Section 115WD to Section 115WM)
Chapter XX-B - REQUIREMENT AS TO MODE OF ACCEPTANCE, PAYMENT OR REPAYMENT IN CERTAIN CASES TO COUNTERACT EVASION OF TAX (From Section 269SS to Section 269TT)
Income deemed to accrue in India where business connection or significant economic presence ties income to Indian operations. Income of non residents is deemed to accrue or arise in India if it is derived through a business connection in India, from property, assets or sources in India, or by transfer of a capital asset situate in India; only the portion reasonably attributable to operations in India is taxable. Business connection includes persons habitually concluding contracts, maintaining stock for delivery, or securing orders, and extends to significant economic presence through prescribed transactions or systematic interaction. Specified heads-salaries earned in India, certain dividends, interest, royalty and fees for technical services-are treated as Indian income subject to defined exceptions and explanatory definitions.
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.
Income deemed to accrue in India where business connection or significant economic presence ties income to Indian operations.
Income of non residents is deemed to accrue or arise in India if it is derived through a business connection in India, from property, assets or sources in India, or by transfer of a capital asset situate in India; only the portion reasonably attributable to operations in India is taxable. Business connection includes persons habitually concluding contracts, maintaining stock for delivery, or securing orders, and extends to significant economic presence through prescribed transactions or systematic interaction. Specified heads-salaries earned in India, certain dividends, interest, royalty and fees for technical services-are treated as Indian income subject to defined exceptions and explanatory definitions.
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