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Offshore funds- Under section 9A

PRESENCE OF ELIGIBLE FUND MANAGER IN INDIA NOT TO CONSTITUTE BUSINESS CONNECTION IN INDIA OF SUCH ELIGIBLE INVESTMENT FUND ON

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Royalty [Section 9(1)(vi)] Explanation

Royalty will be deemed to accrue or arise in India when it is payable by – (a)  the Government; (b)

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Income through transfer of a capital asset situated in India -Explanation to section 9(1)(i)

Income through transfer of a capital asset situated in India -Explanation to section 9(1)(i) (d) Capital gains arising through or

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Business Connection Explanation to section 9(1)(i)

‘Business connection’ shall include any business activity carried out through a person acting on behalf of the non-resident [Explanation 2

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Income deemed to accrue or arise in India [Section 9]

Certain types of income are deemed to accrue or arise in India even though they may actually accrue or arise

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Income ‘accruing’ and ‘arising’

Accrue refers to the right to receive income, whereas due refers to the right to enforce payment of the same.

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Income received or deemed to be received- Meaning

All assessees are liable to tax in respect of the income received or deemed to be received by them in

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