Deemed Indian-source capital gains: indirect transfers taxed if foreign shares derive substantial value from India. Capital gains arising through or from the transfer of a capital asset situated in India are deemed to accrue or arise in India regardless of asset type, document registration location, or payment place; shares or interests in foreign entities are deemed situated in India if they derive their value substantially from assets located in India, determined by tests using a specified date, fair market value and the proportion of India-located assets, subject to proportional taxation where not all assets are India-located.