AI OCR 
TaxTMI 
TaxTMI 
TaxTMI 
Income deemed to accrue or arise in India.
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....hall be deemed to accrue or arise in India. (5)(a) Income by way of interest payable by-- (i) the Government; (ii) a resident, except where it is payable in respect of any debt incurred, or moneys borrowed and used, for the purpose of- (A) a business or profession carried on by such resident outside India; or (B) making or earning any income by such resident from any source outside India; or (iii) a non-resident, if it is in respect of any debt incurred, or moneys borrowed and used, for the purposes of a business or profession carried on by such non-resident in India, shall be deemed to accrue or arise in India; (b) for the purposes of clause (a),-- (i) any interest payable by the permanent establishment in India of a non-resident person engaged in the business of banking, to the head office or any other permanent establishment or any other part of such non-resident outside India shall be deemed to accrue or arise in India and shall be chargeable to tax in addition to any income attributable to such permanent establishment in India; (ii) such permanent establishment in India shall-- (A) be deemed to be....
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....eo tapes for use in connection with television; or (B) tapes for use in connection with radio broadcasting; (vii) the rendering of services in connection with the activities referred to in sub-clauses (i) to (vi); (c) for the purposes of clause (b),-- (i) the transfer or grant of all or any rights in respect of any right, property or information includes transfer or grant of all or any right for use or right to use a computer software (including granting of a licence) irrespective of the medium through which that right is transferred; (ii) royalty includes consideration in respect of any right, property or information, whether or not-- (A) the possession or control of that right, property or information is with the payer; (B) that right, property or information is used directly by the payer; (C) the location of that right, property or information is in India; (iii) the expression "process" includes transmission by satellite (including up-linking, amplification, conversion for down-linking of any signal), cable, optic fibre or by any other similar technology, whether or not that process is secret; (i....
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....esident and the contracts are- (I) in the name of the non-resident; or (II) for the transfer of the ownership of, or for the granting of the right to use, property owned by that non-resident or that non-resident has the right to use; or (III) for the provision of services by the non-resident; or (B) has no such authority, but habitually maintains in India a stock of goods or merchandise from which he regularly delivers goods or merchandise on behalf of the non-resident; or (C) habitually secures orders in India, mainly or wholly for the non-resident, or for that non-resident and other non-residents controlling, controlled by, or subject to the same common control, as that non-resident; (ii) a business activity carried out through a person who is a broker, general commission agent or any other agent, through whom such activity is carried out, and who is working mainly or wholly on behalf of-- (A) a non-resident (referred to as the principal non-resident); or (B) such non-resident and other non-residents who- (I) are controlled by the principal non-resident; or (II) have a controlling interest i....
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.... not apply to the transactions or activities which are confined to the purchase of goods in India for the purpose of export; (f) in this section, only the income which is reasonably attributable to-- (i) operations carried out in India, when all operations of the business are not carried out in India; (ii) transactions or activities referred to in clause (d), shall be deemed to accrue or arise in India from any business connection; (g) the income attributable to operations of any business or significant economic presence in this section shall also include income from-- (i) such advertisement which targets a customer who resides in India or a customer who accesses the advertisement through internet protocol address located in India; (ii) sale of data collected from a person who resides in India or from a person who uses internet protocol address located in India; and (iii) sale of goods or services using data collected from a person who resides in India or from a person who uses internet protocol address located in India. (10) In sub-section (2),-- (a) an asset or a capital asset, being any share of, or interest in, a....
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....ing the date on which the company or entity ceases to exist, in a case where the company or the entity ceases to exist before the end of the accounting period; (f) in case of assets mentioned in clause (a), if-- (i) there is a transfer outside India of any share of, or interest in, a company or an entity registered or incorporated outside India by a non-resident transferor; and (ii) all the assets owned, directly or indirectly, by that company or entity are not located in India, then, the income referred to in sub-section (2) shall be only such part of the income as is reasonably attributable to assets located in India and determined in the manner, as may be prescribed; (g) the income referred to in sub-section (2) shall not include income from transfer, outside India, of any share of, or interest in, a company or an entity registered or incorporated outside India,-- (i) if such share of, or interest in, a company or an entity registered or incorporated outside India is held by a non-resident by way of investment, directly or indirectly,-- (A) in Category I or Category II foreign portfolio investor under the Securities ....