Tax query

Suppose a non resident buys shares of indian company and he makes roi as agent for collection of interest under sec9 of It Act . will dis dividend icome will deemed to accrue or arise in india.
Replies (1)

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."

 

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