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<h1>Income-Tax Act, Section 9: Tax Implications for Foreign Companies Outsourcing to Indian BPOs Explained.</h1> Section 9 of the Income-tax Act, 1961, addresses the taxation of Business Process Outsourcing (BPO) units in India. A non-resident or foreign company with a business connection or permanent establishment in India is subject to tax on profits attributable to activities conducted in the country. The circular clarifies that when non-residents outsource incidental activities to Indian BPOs, the income deemed to arise in India is limited to the BPO's income if the pricing is at arm's length. However, if core revenue-generating activities are outsourced, a significant portion of profits is attributable to the Indian entity and taxable under Indian law.