In May and June 2021, CA Rutvik Sanghvi and CA Ganesh Rajgopalan did a deep dive study of Section 9 of the Income-tax Act – one of the fundamental provisions relevant for a non-resident’s tax exposure in India. The Section has been amended quite frequently in the recent past and led to various controversies. They were invited by the SIRC of ICAI to explain the provisions and the issues therein over two 4-hour sessions in May and June 2021. The analysis is divided into two parts:

1. Fundamental aspects of Section 9:

2. Deemed accrual under Section 9:

CA Ganesh Rajgopalan, the co-author, can be contacted at [email protected]