Section 9A → Section 10
Certain activities not to constitute business connection
Quick Answer
Section 9A of the Income Tax Act, 1961 (Certain activities not to constitute business connection) corresponds to Section 10 of the Income-tax Act, 2025, effective 1st April 2026. Status: Retained.
What changed for Section 9A
The starting point is Section 9A of the Income Tax Act, 1961 — certain activities not to constitute business connection. Safe harbor for offshore funds so that their fund managers in India do not constitute an Indian business connection.
Under the Income-tax Act, 2025 (effective 1st April 2026), Section 9A is retained and renumbered as Section 10 of the Income-tax Act, 2025. Retained to keep India attractive as an international financial center.
The transition impact on Section 9A is assessed as High. Essential for the offshore asset management industry.
Sec 9A
Provision Summary
Safe harbor for offshore funds so that their fund managers in India do not constitute an Indian business connection.
Sec 10
Provision Summary
Retained to keep India attractive as an international financial center.
Key Changes & Highlights
- Compliance conditions relaxed slightly for GIFT City IFSC funds.
Related Sections
Frequently Asked Questions
Which subject does Section 9A of the 1961 Act cover?
Section 9A of the Income Tax Act, 1961 covers certain activities not to constitute business connection. Safe harbor for offshore funds so that their fund managers in India do not constitute an Indian business connection.
What is the new section number for Section 9A under the Income-tax Act, 2025?
Section 9A of the Income Tax Act, 1961 maps to Section 10 of the Income-tax Act, 2025, effective 1st April 2026 (status: Retained). Retained to keep India attractive as an international financial center.
How does the Income-tax Act, 2025 affect Section 9A in practice?
The transition impact for Section 9A is rated High. Essential for the offshore asset management industry.
What is new about Section 9A under the Income-tax Act, 2025?
Compliance conditions relaxed slightly for GIFT City IFSC funds. These points are specific to Section 9A (Certain activities not to constitute business connection).
Disclaimer: This mapping of Section 9A (Certain activities not to constitute business connection) to Section 10 of the Income-tax Act, 2025 is for educational and reference purposes only, based on publicly available drafts and circulars. As Section 9A is currently marked Retained, always confirm its treatment with a qualified Chartered Accountant before filing or making compliance decisions.
Need professional help on Section 9A?
Compare trusted providers — both offer CA services ready for the Income-tax Act, 2025.
*Affiliate links — we may earn a small commission at no extra cost to you. Disclosure.
Want to calculate tax on this section?