Deemed India source income: foreign receipts treated as India sourced when statutory connection or recipient criteria are met. Section 9 treats specified foreign receipts as deemed to accrue or arise in India, including income from a business connection in India, income from property or assets or sources in India, transfers of capital assets situated in India, salaries for services rendered in India, government paid salaries to Indian citizens for foreign services, dividends paid by Indian companies abroad, and interest, royalties and technical service fees payable by or to residents as specified. A deeming rule applies to certain gifts paid by Indian residents to non residents or specified persons when statutory conditions under section 56(2)(x) are satisfied and temporal and recipient criteria are met.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Deemed India source income: foreign receipts treated as India sourced when statutory connection or recipient criteria are met.
Section 9 treats specified foreign receipts as deemed to accrue or arise in India, including income from a business connection in India, income from property or assets or sources in India, transfers of capital assets situated in India, salaries for services rendered in India, government paid salaries to Indian citizens for foreign services, dividends paid by Indian companies abroad, and interest, royalties and technical service fees payable by or to residents as specified. A deeming rule applies to certain gifts paid by Indian residents to non residents or specified persons when statutory conditions under section 56(2)(x) are satisfied and temporal and recipient criteria are met.
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