Income deemed to accrue or arise in India - section 9(1)(i) - trading of goods

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... ise in India to a non-resident through or from operations which are confined to the purchase of goods in India for the purpose of export. Prior to 1-4-1964, this clause of the Explanation was subject to a proviso which read as under:- "Provided that the non-resident has no office or agency in India for this purpose and the goods are not subjected to any kind of manufacturing process before being .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... d in India are subjected to any manufacturing process, the profits attributable to the manufacturing operations will be exempt from tax. 3. A further question that arises about the scope of Section 9(1)(i) is whether the profit attributable to the operation of purchase of goods in India will also become taxable where the goods are subjected to any separately identifiable process by or on behalf o .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X