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SECTION 9 OF THE INCOME-TAX ACT, 1961 – INCOME – DEEMED TO ACCRUE OR ARISE IN INDIA

Capital gains – Shares/units, transfer of : Where assessee, a Singapore based company, claimed exemption on capital gains arising from sale of shares of an Indian company under India-Singapore DTAA, since assessee had discharged initial burden by filing statutory evidence of tax residency in form of TRC and same was not rebutted by any inquiry or evidence by Assessing Officer, assessee was to be allowed exemption – Tyco Electronics Singapore Pte Ltd. v. Deputy Commissioner of Income-tax (International Taxation) – [2024] 166 taxmann.com 491 (Delhi – Trib.)

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