{"query":"What is the Income-tax Act 2025 successor of s.9(1)(i) Explanations 4A–7 (indire","matches":[{"id":"auto_map_s_9_1_i_explanations_4a_7_indirect_transfer","question":"What is the Income-tax Act 2025 successor of s.9(1)(i) Explanations 4A–7 (indirect transfer)?","answer":"s.9(1)(i) Explanations 4A–7 (indirect transfer) (Income-tax Act, 1961) became s.9(10) (Income-tax Act, 2025) with effect from 2026-04-01 — Indirect transfer — share/interest deriving substantial value from Indian assets. INR 10 crore + 50% substantiality at s.9(10)(b); 5% small-holder carve-outs at (10)(g).","pinpoint":"s.9(10), Income-tax Act 2025 (verified: official CBDT text, 14 Aug 2026)","confidence":"settled","as_at":"14 Aug 2026","match_score":2},{"id":"auto_map_s_9_1_vi_explanation_2","question":"What is the Income-tax Act 2025 successor of s.9(1)(vi) Explanation 2?","answer":"s.9(1)(vi) Explanation 2 (Income-tax Act, 1961) became s.9(6)(b) (Income-tax Act, 2025) with effect from 2026-04-01 — Definition of royalty. Limbs (i)-(vii); equipment limb at (b)(v), copyright limb at (b)(vi).","pinpoint":"s.9(6)(b), Income-tax Act 2025 (verified: official CBDT text, 14 Aug 2026)","confidence":"settled","as_at":"14 Aug 2026","match_score":1},{"id":"auto_map_s_9_1_vi_explanation_4","question":"What is the Income-tax Act 2025 successor of s.9(1)(vi) Explanation 4?","answer":"s.9(1)(vi) Explanation 4 (Income-tax Act, 1961) became s.9(6)(c)(i) (Income-tax Act, 2025) with effect from 2026-04-01 — Software-deeming — right to use computer software is royalty. Domestic deeming stands under the 2025 Act; Engineering Analysis relieves only THROUGH the treaty via s.159(4). NOTE: Sub-clause is ROMAN (i). The '(c)(1)' numbering circulating in secondary reproductions is imprecise — corrected against the official text this session.","pinpoint":"s.9(6)(c)(i), Income-tax Act 2025 (verified: official CBDT text, 14 Aug 2026)","confidence":"settled","as_at":"14 Aug 2026","match_score":1}],"engine":"deterministic","llm_in_path":false}