Business connection taxable scope: apportion profits to operations in India, including services by personnel sent under agreement. The Board confirms that only profits reasonably attributable to operations carried out in India are taxable under Section 9; while accepting that a non-resident's obligation to send technical personnel to India constitutes services rendered in India and may create taxable activity, it directs continuation of the existing practice of apportioning income under the Explanation to Section 9(1)(i). In attributing income to Indian operations, services rendered in India by technical or other personnel sent by the non-resident must be taken into consideration.