TMI BlogIncome deemed to accrue in India.X X X X Extracts X X X X X X X X Extracts X X X X ..... f the provisions of sub-section (1), the following income shall be deemed to accrue in India , namely:— (a) income from employment, if it is for– (i) service rendered in India ; (ii) service rendered outside India by a citizen of India and the income is receivable from the Government; or (iii) the rest period, or leave period, which precedes, or succeeds, the period of service rendered in India and forms part of the service contract of employment; (b) any dividend paid by a domestic company outside India ; (c) any insurance premium including re-insurance premium accrued from or payable by any resident or non-reside ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... For the purposes of clause (a) of sub-section (1), in the case of a business of which all the operations are not carried out in India, the income of the business deemed to accrue in India shall be only such part of the income as is reasonably attributable to the operations carried out in India. (4) The income deemed to accrue in India under sub-section (1) shall, in the case of a non-resident, not include the following, namely:— (a) any income accruing through, or from, operations which are confined to the purchase of goods in India for the purposes of export out of India ; (b) interest accrued from or payable by a resident, in respect of any debt incurred and used for the purposes of— ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e from transfer, outside India, of any share or interest in a foreign company unless at any time in twelve months preceeding the transfer, the fair market value of the assets in India, owned, directly or indirectly, by the company, represent at least fifty per cent. of the fair market value of all assets owned by the company; (h) interest accrued from or payable by a non-resident as referred to in sub-clause (ii) of clause (e) of sub-section (2), if such interest has not been claimed by the non-resident as a deduction from his tax bases chargeable in India . (5) The provisions of clauses (c) to (k) of sub-section (2) shall be applicable, whether or not,— (a) the payment is made in India ; ..... X X X X Extracts X X X X X X X X Extracts X X X X
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