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Knowledge Bank / Income-tax Act, 2025 / Chapter XXIII - Miscellaneous

Section 506

Section 506: Indian concern must furnish information on indirect asset transfers

Section 506 targets the classic "indirect transfer" situation, where a foreign company or entity's value comes substantially from assets located in India, held through an Indian concern. That Indian concern is required to furnish information or documents to help the tax authority determine the income accruing or arising in India under section 9(10)(a).

This explanation is AI-assisted and pending review by our CA/CS team. It is general information, not professional advice - always cross-check against the bare law text above or talk to our tax team for guidance specific to your situation.

When the obligation applies

The section applies where:

  • a share of, or interest in, a company or entity registered or incorporated outside India derives, directly or indirectly, its value substantially from assets located in India, as referred to in section 9(10)(a); and
  • such company or entity holds, directly or indirectly, such assets in India through, or in, an Indian concern.

What the Indian concern must do

In that situation, the Indian concern must, for the purposes of determining any income accruing or arising in India under section 9(10)(a), furnish within the prescribed period, to the prescribed income-tax authority, the information or documents in such manner as may be prescribed.

Frequently asked questions

Who has the reporting obligation under Section 506?

The Indian concern through which a foreign company or entity, deriving substantial value from India-located assets, holds those assets - not the foreign entity itself.

What is this information used for?

Determining income accruing or arising in India under section 9(10)(a), which deals with indirect transfers of Indian assets.

Want this applied to your actual filing, not just explained?

Talk to our tax team about this section

Last updated 9 September 2026

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