CA
742 Points
Posted on 11 May 2013
As per the Guidance Note issued by ICAI,
"A dividend declared by an Indian company would be deemed to accrue in India if the source of income is situated in India. But what happens when dividend is declared in India and paid to a non-resident out of India.
To cover such a situation, section 5(2)(b) has to be read with section 9(1)(iv). Under section 9(1)(iv), it is clearly stipulated that a dividend paid by an Indian company outside India will constitute income deemed to accrue in India on effecting such payment."