Business connection in India determines when non-resident income is taxable based on activities, agents, or significant economic presence. Income of a non-resident is deemed to accrue or arise in India if it arises through or from any business connection in India, through property or assets in India, or through transfer of capital assets situated in India. A business connection includes activities by a person acting on behalf of the non-resident who habitually concludes contracts, maintains stock for regular delivery, or habitually secures orders in India. Significant Economic Presence also constitutes business connection, and only income reasonably attributable to operations in India is deemed to accrue in India.
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.
Business connection in India determines when non-resident income is taxable based on activities, agents, or significant economic presence.
Income of a non-resident is deemed to accrue or arise in India if it arises through or from any business connection in India, through property or assets in India, or through transfer of capital assets situated in India. A business connection includes activities by a person acting on behalf of the non-resident who habitually concludes contracts, maintains stock for regular delivery, or habitually secures orders in India. Significant Economic Presence also constitutes business connection, and only income reasonably attributable to operations in India is deemed to accrue in India.
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