Income deemed to accrue in India

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....p; (c) an asset or source of income in India; or     (d) the transfer, directly or indirectly, of a capital asset situate in India. (2) Without prejudice to the generality of the provisions of sub-section (1), the following income shall be deemed to accrue in India: -     (a) income from employment, if it is for-        (....

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.... or        (ii) earning any income from any source in India;     (e) royalty accrued from the Government or any resident;     (f) royalty accrued from a non-resident, if the royalty is for the purposes of -        (i) a business carried on by the non-resident in India; or     &nb....

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....ub-section (1), in the case of a business of which all the operations are not carried out in India, the income of the business deemed to accrue in India shall be only such part of the income as is reasonably attributable to those operations carried out in India. (4) The income deemed to accrue in India under sub-section (1) shall, in the case of a non-resident, not include the following :- &....

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....ng of lump sum consideration accrued from a resident for the transfer of any rights (including the granting of a licence) in respect of computer software supplied by a non-resident manufacturer, along with a computer or computer-based equipment, under any scheme approved under the Policy on Computer Software Export, Software Development and Training, 1986 of the Government of India.   &nbs....