S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection-Security–Shares-Sale of units of equity linked mutual funds and derived short term capital gain (STCG)-Exempt to tax in India – DTAA–India–UAE [S.5(2), Indian Companies Act, 2013, S.2(84), Securities Contract (Regulation) Act, 1956. Art. 3(2), 13(4)]