Avoidance of income-tax by transactions resulting in transfer of income to non-residents

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....onjunction with associated operations, any income becomes payable to a non-resident, the following provisions shall apply- (a) where any person has, by means of any such transfer, either alone or in conjunction with associated operations, acquired any rights by virtue of which he has, within the meaning of this section, power to enjoy, whether forthwith or in the future, any income of a non-resi....

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....e provisions of this section, be deemed to be the income of the first-mentioned person for all the purposes of this Act. Explanation.-The provisions of this sub-section shall apply also in relation to transfers of assets and associated operations carried out before the commencement of this Act. (2) Where any person has been charged to income-tax on any income deemed to be his under the provision....

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....ude references to shares in or obligation of any company to which, or obligation of any other person to whom, those assets, that income or those accumulations are or have been transferred; (b) any body corporate incorporated outside India shall be treated as if it were a non-resident; (c) a person shall be deemed to have power to enjoy the income of a non-resident if- (i) the income is in fa....

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....ocation or otherwise to obtain for himself, whether with or without the consent of any other person, the beneficial enjoyment of the income, or (v) such first-mentioned person is able, in any manner whatsoever and whether directly or indirectly, to control the application of the income; (d) in determining whether a person has power to enjoy income, regard shall be had to the substantial result....