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of <h1>Section 9 comparison: As Passed versus introduced Bill on incomes deemed to arise in India, with drafting and scope differences</h1> The comparison shows Section 9 in the As Passed and the originally introduced Bill both broadly deem specified incomes (source, salaries, dividends, interest, royalty, technical fees, business connection/SEP, and transfers of capital assets) to arise in India, but differ in drafting, clause ordering, cross-references and some clarifications. Key substantive distinctions include an explicit royalty exclusion reference in the As Passed, clearer treatment of interest attributable to an Indian permanent establishment, rephrased salary hooks, and slightly altered tests/references for transfers of foreign shares and associated enterprises. Both rely on prescribed thresholds for significant economic presence and subordinate rules, so operational impact depends on regulations and factual thresholds.
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