Income Deemed to Accrue or Arise in India: A Comparative Analysis of Current and Proposed Provisions

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....5, compared to the existing provisions u/ss 9 and 9A of the Income-tax Act, 1961. The provisions deal with income deemed to accrue or arise in India and have significant implications for both residents and non-residents. 2. Objective and Purpose The primary objectives of these provisions are: * To define the territorial nexus for taxing income in India * To establish clear criteria for busin....

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....: * Comprehensive framework for digital transactions * Specific provisions for: * Online advertising targeting Indian customers * Data collection and monetization * Digital services 3.4 Investment Fund Management * Integration of Section 9A provisions * Modified conditions for eligible investment funds * Enhanced clarity on fund manager activities 4. Practical Implications 4.1 F....