Income deemed to accrue or arise in India - “Through or from any business connection in India.” - Section 9(1)(i)

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....n" shall include any business activity carried out through a person who, acting on behalf of the non-resident. [ Explanation 2 of Section 9(1)(i) ] * In case he have an authority, which is habitually exercises in India, to conclude contracts on behalf of the non-resident or * habitually concludes contracts or habitually plays the principal role leading to conclusion of contracts by that non-resident and the contracts are-- * in the name of the non-resident; or  * for the transfer of the ownership of property owned by that non-resident, or  * for the granting of the right to use, that non-resident has the right to use; or  * for the provision of services by the non-resident; or * In case he has no such ....

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....her agent having an independent status, if such broker, general commission agent or any other agent having an independent status is acting in the ordinary course of his business.  * A broker, general commission agent or any other agent having an independent status where he does not works mainly or wholly on behalf of a non-resident * However, he will not be considered having independent status where he carries on business as referred to in above points of a, b & c of Section 9(1)(i). only so much of income as is attributable to the operations carried out in India shall be deemed to accrue or arise in India. In the case of a Non-resident the following shall not be treated as Business Connection in India [ Explanation 1 of Section 9....

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....r * the non-resident has a residence or place of business in India; or * the non-resident renders services in India: * However, where a business connection is established by reason of SEP only so much of income as is attributable to the transactions or activities referred to in clause (A) or clause (B) shall be deemed to accrue or arise in India. * The transactions or activities which are confined to the purchase of goods in India for the purpose of export shall not constitute significant economic presence in India. [ Inserted vide Section 4 of Finance Act, 2025 W.e.f. 01.04.2026 ] * Income as is reasonably attributable to the operations carried out in India includes income from -  * (i) such advertisement which....

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....lanation 1(d) of section 9(1)(i) ] * In the case of a non-resident, being -  * an individual who is not a citizen of India; or * a firm which does not have any partner who is a citizen of India or who is resident in India; or * a company which does not have any shareholder who is a citizen of India or who is resident in India, * no income shall be deemed to accrue or arise in India to such individual, firm or company through or from operations which are confined to the shooting of any cinematograph film in India. * Activities confined to display of rough diamonds in Special Notified Zones [ Explanation 1(e) of Section 9(1)(i) ] * In the case of a foreign company engaged in the business of mining of diamonds....