Attribution of transfer income to Indian assets requires formula-based apportionment, taxpayer reporting, and accountant certification. Income attributable to the transfer outside India of a share in, or interest in, a company or entity covered by section 9(10)(a) is determined by apportioning the transfer income according to the ratio of the fair market value of assets located in India to the fair market value of all assets, with both values computed under rule 11. If the transferor does not provide the necessary information, the income is determined as the Assessing Officer considers suitable. The transferor must also furnish a Form No. 4 accountant's report with the return of income.