Explanation 5 of Income Tax Act Section 9(1)(i) has retrospective effect, supported by new Explanations 6 and 7.

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....Income accrued in India - section 9(1)(i) - Explanation 5 has been given retrospective effect and Explanations 6 and 7 have been inserted in furtherance of the object of insertion of Explanation 5, these two explanations cannot be read in isolation, but have to be tagged alongwith Explanation 5 so that both the Explanations have to be given a retrospective effect - AT....