Deemed accrual in India: income from resident transfers abroad treated as accruing in India, expanding tax reach. The amendment inserts a new clause in section 9 deeming any sum of money paid or any property situated in India transferred by a resident to a person outside India as income accruing or arising in India, thereby extending source-based taxation to such outward transfers and applying prospectively from the specified assessment year.
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Provisions expressly mentioned in the judgment/order text.
Deemed accrual in India: income from resident transfers abroad treated as accruing in India, expanding tax reach.
The amendment inserts a new clause in section 9 deeming any sum of money paid or any property situated in India transferred by a resident to a person outside India as income accruing or arising in India, thereby extending source-based taxation to such outward transfers and applying prospectively from the specified assessment year.
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