Income-tax Act, 2025
Income deemed to accrue or arise in India. - Section 9
Income deemed to accrue or arise in India.
9. (1) The income referred to in sub-sections (2) to (8) shall be deemed to accrue or arise in India.
(2) The income accruing or arising, directly or indirectly, through or from
(a) any asset or source of income in India; or
(b) any property in India; or
(c) any business connection in India; or
(d) the transfer of a capital asset situated in India,
shall be deemed to accrue or arise in India.
(3) Any income falling under the head "Salaries" shall be deemed to accrue or arise in India, if it is
(a) earned in India, and any income payable for,
(i) services rendered in India; and
(ii) the rest period or leave period which is preceded and succeeded by services rendered in India and forms part of the service contract of employment,
shall be regarded as income earned in India;
(b) payable by the Government to an Indian citizen for services rendered outside India.
(4) Any dividend paid by an Indian company outside India shall 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 e
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