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Amendment of section 9.

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....moval of doubts, it is hereby clarified that the expression "through" shall mean and include and shall be deemed to have always meant and included "by means of", "in consequence of" or "by reason of". Explanation 5.--For the removal of doubts, it is hereby clarified that an asset or a capital asset being any share or interest in a company or entity registered or incorporated outside India shall ....

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....clarified that the royalty includes and has always included consideration in respect of any right, property or information, whether or not-- (a) the possession or control of such right, property or information is with the payer; (b) such right, property or information is used directly by the payer; (c) the location of such right, property or information is in India. Explanation 6.--For the....

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....apital asset situate in India shall be deemed to accrue or arise in India. It is proposed to insert a new Explanation 4 in the aforesaid clause so as to clarify the expression "through" used in the said sub-section. It is further proposed to insert a new Explanation 5 in the aforesaid clause (i) so as to clarify that an asset or a capital asset being any share or interest in a company or entity ....

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Full Text of the Document

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....ch right is transferred. It is also proposed to insert a new Explanation 5 in the aforesaid clause so as to clarify that the royalty includes and has always included consideration in respect of any right, property or information, whether or not -- (a) the possession or control of such right, property or information is with the payer; (b) such right, property or information is used directly by t....