Section 9 Interpretation: No 'Look Through Provision' for Asset Situs Change Without Legislative Action.

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....Section 9 has no 'look through provision' and such a provision cannot be brought through construction or interpretation of a word ‘through’ in Section 9. In any view, 'look through provision' will not shift the situs of an asset from one country to another. Shifting of situs can be done only by express legislation. .... - SC....