On 21 December 2016, the Indian Central Board of Direct Taxes issued Circular No. 41 of 2016 to provide clarifications on indirect transfer provisions under the Income Tax Act 1961 (ITA) through a series of question and answers (Q&A). The Q&A sets out different scenarios in which income will be deemed to accrue or arise in India, taking into account the provisions of section 9(1)(i) of …