S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection-Income will be assessed in the hands of PQR and STU and benefit of article 13 of the India-Netherlands Double Taxation Avoidance Agreement is not admissible to these funds will be assessed in the hands of PQR and STU and benefit of article 13 of the India-Netherlands Double Taxation Avoidance Agreement is not admissible to these funds-DTAA-India-Netherlands. [S. 2(17), 5, 60, 61, 62, 63(a), 160(1)(iv), Art, 13]