As per Section 9,

Income accrued or arised in India are taxable for all assessees

These include the following types of Incomes


1. Income from a Business Connection in India

Business Connection means a branch/agent/organization in India of a non-resident

In case income partly carried out in India and partly outside India, Income which is reasonably attributable to operations in India to be considered


Following shall not be considered as Business Connection in case of Non Resident

  1. Purchasing goods from India by All Non Residents
  2. Collection of news by News agency by All Non Residents
  3. Shooting of cinematographic films in India by following non residents only
  • Individua l :-who is not a citizen of India
  • Firm: -whose all partners not citizen of India and not resident in India
  • Company :- whose all shareholders not citizen of India and not resident in India


  2. Income from any property/asset/source of Income in India

  • Property may be movable or immovable
  • It doesn’t matter whether rent or income on such property is received in India or outside India. If property or asset is situated in India, it is taxable for all assessees


3.  Interest/Royalty/fees for Technical Service paid by

  • Government
  • Resident (except when it is for earning income outside India)
  • Non Resident(provided it is for the purpose of business or profession in India)

These wil be taxable whether or not

non-resident has a residence or place of business or business connection in India


non-resident has rendered services in India.

  4. Any Income from Salaries for service rendered in India

It doesn’t matter where salary is received, it may be received in India or outside India

5.  Income on Transfer of Capital Asset situated in India

Buyer and seller may be non-resident but if the property is situated in India, it is deemed to accrue or arise in India and hence taxable in India

6.Salary paid by Government to Indian Citizen for Services Rendered outside India

Note:-All allowances/perquisites are exempt, only Basic Salary taxable as deemed to accrue or arise in India

Salary should be paid to Indian Citizen, who may be resident or non-resident


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CA Maninder Singh

CA Maninder Singh is a Chartered Accountant for the past 14 years. He also provides Accounts Tax GST Training in Delhi, Kerala and online.