IT/ILT : As per Explanation 1 to section 9(1)(i) , in case of an assessee a tax resident of Hongkong whose business operations are not exclusively carried out in India, amount of income which will be deemed to accrue or arise in India shall be only such part of income as is reasonably attributable to operations carried out in India. Therefore, income which is deemed to accrue or arise in India must have a territorial nexus.
from www.taxmann.com Latest Case Laws https://www.taxmann.com/topstories/101010000000186691/‘fox-international’-not-liable-to-pay-tax-on-agency-commission-in-absence-of-territorial-nexus-with-india.aspx
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