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Section 9(1) Contd. - Explanations to Section 9(1) (i) - Apportionment of Income Where All Business Operations Not Carried Out in India [Clause (a) of Explanation 1] - Determination of income deemed to accrue or arise in India
Section 9(1) Contd. - Business Connection : Clause (i) of Sub-Section (1) of Section 9 - APPORTIONMENT OF INCOME WHERE ALL BUSINESS OPERATIONS NOT CARRIED OUT IN INDIA : EXPLANATION 1(a) TO SECTION 9(1)(i) - --
Section 9(1) Contd. - Business Connection : Clause (i) of Sub-Section (1) of Section 9 - Introductory - Territorial nexus no more required to be established by virtue of Explanation to section 9
Section 9(1) Contd. - Business Connection : Clause (i) of Sub-Section (1) of Section 9 - Introductory - Assessee’s executives carrying out supervising activities in India and their stay in India exceeded 180 days—Whether assessee can be said to have PE in India
Section 9(1) Contd. - Business Connection : Clause (i) of Sub-Section (1) of Section 9 - Introductory - Commission payment to non-resident agent for services rendered outside India Whether accrues or arises in India
Section 9(1) Contd. - Business Connection : Clause (i) of Sub-Section (1) of Section 9 - Introductory - Payment towards advisory services under agreement Taxability in India
Section 9(1) Contd. - Business Connection : Clause (i) of Sub-Section (1) of Section 9 - Introductory - Amount reimbursed to head office Not to constitute income of head office
Section 9(1) Contd. - Business Connection : Clause (i) of Sub-Section (1) of Section 9 - Introductory - Assessee selling CKD units and CBU units to its subsidiary in India Whether income can be treated as arisen from business connection?
Section 9(1) Contd. - Business Connection : Clause (i) of Sub-Section (1) of Section 9 - Introductory - Support services provided by branch office in India, whether income accrues in India
Section 9(1) Contd. - Business Connection : Clause (i) of Sub-Section (1) of Section 9 - Introductory - Referral fees received by UK based company from Indian company Whether taxable