Comprehensive Analysis of Section 9(12) of the Income Tax Act, 2025 — Statutory Construction, International Tax Principles, Schedule I Interaction, and IFSCA Regulatory Integration
Part I: Preliminary — Structural Context of the Income Tax Act, 2025 1.1 The Recodification Landscape Section 9 in the 2025 Act carries forward the substantive content of Section 9 and Section 9A of the 1961 Act, but restructures and consolidates them. What was formerly Section 9A (certain activities not constituting business connection) is now codified as Section 9(12) read with