Under section 9 of the Income-tax Act, 2025, salary paid by an Indian company to its employee for…

Section 9(3) of the Income-tax Act, 2025 deems salary to accrue or arise in India only if it is earned in India, that is, payable for services rendered in India, or if it is payable by the Government to an Indian citizen for services rendered outside India. Salary paid by a company for services rendered at its branch abroad meets neither test, so it is "Salary accruing or arising outside India"; the nationality of the employer and the currency of payment make no difference. This corresponds to section 9 of the repealed Income-tax Act, 1961.