Launch offer — 25% off with code LAUNCH-25 See plans →
Microlesson · 5-min read

Section 9(1)(ii)-(iv) – Salaries, Government Salary Abroad, Dividends

# Salaries, Government Salary & Dividends Deemed to Accrue in India

## Salary for services rendered in India – Section 9(1)(ii)

  • Salary for services rendered in India is deemed to accrue in India.
  • Salary for a leave or rest period linked to services rendered in India is also deemed to accrue here — provided it forms part of the terms of the service contract.

> Rule of thumb: salary follows the place where service is rendered, not where it is paid.

## Government salary for services rendered outside India – Section 9(1)(iii)

  • Salary payable by the Government of India to a citizen of India for services rendered outside India is deemed to accrue in India.
  • The citizen may be resident or non-resident — it does not matter.
  • If the recipient is not an Indian citizen, this section does not apply → such salary is not taxable in India.
  • Exemption: Allowances and perquisites paid outside India by the Government are exempt under Section 10(7). (Only the basic salary is taxed.)

## Dividends – Section 9(1)(iv)

  • Dividends paid by an Indian company outside India are deemed to accrue in India and are taxable in the hands of the shareholder.

## Quick comparison

ProvisionConditionDeemed to accrue in India?
9(1)(ii)Service rendered in IndiaYes
9(1)(iii)Govt salary to Indian citizen for service abroadYes (allowances/perks exempt u/s 10(7))
9(1)(iii)Govt salary to non-citizenNo
9(1)(iv)Dividend by Indian company paid abroadYes

Worked example

### Example 1

Govt salary abroad: Mr. X, an Indian citizen and non-resident, is posted at the Indian Embassy in Paris and paid ₹12,00,000 salary plus ₹4,00,000 foreign allowance by the Government. The ₹12,00,000 salary is deemed to accrue in India and is taxable [Sec 9(1)(iii)]; the ₹4,00,000 allowance is exempt u/s 10(7).

### Example 2

Non-citizen govt employee: A foreign national employed by the Indian Government for service in London is paid salary abroad. Section 9(1)(iii) does not apply (recipient is not an Indian citizen), so it is not deemed to accrue in India.

⚠️ Common exam mistakes

  • Forgetting that allowances and perquisites under a Government posting abroad are exempt under Section 10(7) — students often tax the entire package.
  • Applying 9(1)(iii) to non-citizens — it applies only to citizens of India.
  • Ignoring that residential status is irrelevant for 9(1)(iii) — a non-resident Indian citizen is still caught.
Bare-Act text Section 9(1)(ii), (iii), (iv) · Income-tax Act, 1961 · click to expand
Section 9(1)(ii): income which falls under the head 'Salaries', if it is earned in India. Section 9(1)(iii): income chargeable under the head 'Salaries' payable by the Government to a citizen of India for service outside India. Section 9(1)(iv): a dividend paid by an Indian company outside India.
Now that you've read this — what's next?
Move from understanding → mastery in 3 clicks. Each option below picks up from this lesson's topic.
Start 15-min diagnostic