Section 9 of the Income-tax Act, 1961 - Income - Deemed to accrue or arise in India - Withdrawal of Circulars No. 23 dated 23rd July, 1969, No. 163 dated 29th May, 1975 and No. 786 dated 7th February, 2000
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Deemed income under Section 9 clarified: prior circulars withdrawn and taxpayer interpretations granting unintended relief curtailed by authorities. The Central Board of Direct Taxes withdraws Circular No. 23 (23 July 1969) with immediate effect, and also withdraws Circulars No. 163 and No. 786 which provided clarifications to it, observing that some taxpayers' interpretations sought relief inconsistent with the governing statutory rule on income deemed to accrue or arise in India; the withdrawal is without prejudice to the Department's arguments that the circulars did not apply in particular cases or could not be interpreted to allow relief contrary to statute or intent.
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Deemed income under Section 9 clarified: prior circulars withdrawn and taxpayer interpretations granting unintended relief curtailed by authorities.
The Central Board of Direct Taxes withdraws Circular No. 23 (23 July 1969) with immediate effect, and also withdraws Circulars No. 163 and No. 786 which provided clarifications to it, observing that some taxpayers' interpretations sought relief inconsistent with the governing statutory rule on income deemed to accrue or arise in India; the withdrawal is without prejudice to the Department's arguments that the circulars did not apply in particular cases or could not be interpreted to allow relief contrary to statute or intent.
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