Income deemed to accrue or arise in India - section 9(1)(i) - trading of goods

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....ncome-tax Act, 1961, no income shall be deemed to accrue or arise in India to a non-resident through or from operations which are confined to the purchase of goods in India for the purpose of export. Prior to 1-4-1964, this clause of the Explanation was subject to a proviso which read as under:- "Provided that the non-resident has no office or agency in India for this purpose and the goods are ....

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....o implication in the paragraph quoted above that if the goods purchased in India are subjected to any manufacturing process, the profits attributable to the manufacturing operations will be exempt from tax. 3. A further question that arises about the scope of Section 9(1)(i) is whether the profit attributable to the operation of purchase of goods in India will also become taxable where the good....