[ compiled answer ]
law as at 14 Aug 2026 · settled
Does the domestic stock-of-goods route require sales-contributing activities?
The compiled answer
No. Explanation 2(b) to s.9(1)(i) requires only habitual maintenance of an Indian stock from which the agent regularly delivers on the non-resident's behalf — no sales-contribution conjunct. Article 5(4)(b) of the India–US treaty adds that conjunct, so the treaty is narrower and prevails for a treaty-entitled enterprise (s.90(2)).
Pinpoint
Explanation 2(b) to s.9(1)(i), Income-tax Act 1961
String-verified quote
“habitually maintains in India a stock of goods or merchandise from which he regularly delivers”
source: provision:IN.ITA.S9-1-I — verified at load; a quote that stops matching its source is a compile error
Computed by a deterministic engine over compiled law — no generative model in the evaluation path. JSON twin: /t/domestic_stock_route_no_conjunct.json · Ask with YOUR facts: GET /compute?lookup=… · MCP: POST https://lrlabs.ai/mcp (lookup_compiled_rule)