whole of the profits of a non-resident, accruing or arising from a business connection in India is not deemed to accrue or arise in India, and it is only that portion of the profits which can reasonably be attributed to the operations of business carried out in India, which is liable to income-tax. https://www.taxtmi.com/circulars?id=10374 The Board confirms that only profits reasonably attributable to operations carried out in India are taxable under Section 9; while accepting that a non-resident's obligation to send technical personnel to India constitutes services rendered in India and may create taxable activity, it directs continuation of the existing practice of apportioning income under the Explanation to Section 9(1)(i). In attributing income to Indian operations, services rendered in India by technical or other personnel sent by the non-resident must be taken into consideration. en-us Sat, 27 Sep 1975 00:00:00 +0530 Fri, 17 Jun 2011 18:46:00 +0530 TaxTMI RSS Generator whole of the profits of a non-resident, accruing or arising from a business connection in India is not deemed to accrue or arise in India, and it is only that portion of the profits which can reasonably be attributed to the operations of business carried out in India, which is liable to income-tax. https://www.taxtmi.com/circulars?id=10374 The Board confirms that only profits reasonably attributable to operations carried out in India are taxable under Section 9; while accepting that a non-resident's obligation to send technical personnel to India constitutes services rendered in India and may create taxable activity, it directs continuation of the existing practice of apportioning income under the Explanation to Section 9(1)(i). In attributing income to Indian operations, services rendered in India by technical or other personnel sent by the non-resident must be taken into consideration. Circulars Income Tax Sat, 27 Sep 1975 00:00:00 +0530 https://www.taxtmi.com/circulars?id=10374