Ishikawajima-Harima Heavy Industries Ltd. v. DIT (2007) 158 Taxmann 259 (SC).

Section 9 Indian Income Tax Act 1961, Subsection 9(1)(vii)(b): «Explanation – For the removal of doubts, it is hereby declared that for the purposes of this section, income of a non-resident shall be deemed to accrue or arise in India under clause (v) or clause (vi) or clause (vii) of sub-section (1) and shall be included in the total income of the non-resident, whether or not, (i) the non-resident has a residence or place of business or business connection in India; or (ii) the non-resident has rendered services in India».