Section 4 - Amendment of section 9.

Significant economic presence constitutes business connection, bringing digital transactions and user interactions within India income attribution rules.

The amendment replaces the explanatory clause on agent-linked business connection to specify that an agent who habitually exercises authority to conclude contracts, habitually concludes contracts, or plays the principal role leading to contract conclusion for a non-resident creates a business connection when contracts are in the non-resident's name, transfer or grant rights in the non-resident's property, or provide services. It also adds that significant economic presence constitutes business connection, defined by prescribed-threshold transactions (including data or software downloads) or systematic digital soliciting or user interactions, and that only income attributable to those activities is deemed to accrue in India.