https://www.taxtmi.com/circulars?id=4781 Income embodied in shares allotted to non residents for delivery abroad of machinery and plant will attract Indian income tax because royalties and fees for technical services are deemed to accrue or arise in India under the 1976 amendments; the prior administrative concession in paragraph 11 of Public Circular No. 21 of 1969 is withdrawn and no longer insulates such share based payments from taxation as income received in India. en-us Fri, 04 May 1984 00:00:00 +0530 Sat, 02 Aug 2008 16:24:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/circulars?id=4781 Income embodied in shares allotted to non residents for delivery abroad of machinery and plant will attract Indian income tax because royalties and fees for technical services are deemed to accrue or arise in India under the 1976 amendments; the prior administrative concession in paragraph 11 of Public Circular No. 21 of 1969 is withdrawn and no longer insulates such share based payments from taxation as income received in India. Circulars Income Tax Fri, 04 May 1984 00:00:00 +0530 https://www.taxtmi.com/circulars?id=4781