Tax is considered to be the cost of living in a society. The government levies a tax to make sure that it is able to meet the needs of the people, and it is also the basic source of income of the government. Section 9 of the Income Tax Act, 1995 was designed as an aggregating provision since it amalgamated several independent provisions which had been scattered across the Indian Income Tax Act, 1922. These provisions were collected and put together under the head of ‘incomes deemed to accrue or arise in India’. The section enacts into law a “source rule” of taxation deeming different kinds of incomes, from interest and dividend to salary and royalty, to ‘accrue or arise’ in India for the purpose of taxation. However, it is pertinent to note that these incomes do not accrue or arise in India per se. Hence, through the employment of a legal fiction, these different forms of income have been drawn into the tax net by the legislature due to their significant link with India.

Tax is considered to be the cost of living in a society. The government levies a tax to make sure that it is able to meet the needs of the people