The CBDT has clarified that the purpose of the amendment of section 9(1) (i) was to tax gains having economic nexus with India. It is stated that the as the declaration of dividend by a foreign company outside India does not have the effect of transfer of any underlying assets located in India, the said dividends would not be deemed to be income accruing or arising in India by virtue of the provisions of Explanation 5 to section 9 (1) (i) of the Act. Even if the shares derive their value substantially from assets situated in India

The Finance Minister, in his budget speech, while acknowledging the limitations under the existing law, had conveyed the considered decision of the Government to enact a comprehensive new law on black money to specifically deal with black money stashed away abroad. He also promised to introduce the new Bill in the current Session of the Parliament. In order to fulfil the commitment made by the Government to the people of India through the Parliament, the Undisclosed Foreign Income and Assets (Imposition of Tax) Bill, 2015 has been introduced in the Parliament on 20.03.2015. The Bill provides for separate taxation of any undisclosed income in relation to foreign income and assets. Such income will henceforth not be taxed under the Income-tax Act but under the stringent provisions of the proposed new legislation.

The Finance Bill 2015, as introduced in the Lok Sabha today, 28.02.2015, is available for download

The creation of two additional benches of the Authority would dispose of increased number of cases and pendency of cases would be reduced benefitting the tax payer and the Government. Besides, this will operationalise the facility of advance ruling for resident tax payers. The proposed additional Benches of Authority for Advance Rulings (Income Tax) will facilitate the cause of the resident tax payers in obtaining tax clarity in certain situations