The word property includes both movable and immovable but does not include intangible assets. Intangible property like a debt is not property under the provisions .of this section. A debt due to a foreigner cannot be called as asset or source of income in India, hence interest on such debt cannot be deemed to accrue or arise in India. (C.I.T. v. Saurashtra Cement & chemical Industries Ltd. 101 I.T.R. 502).
In case a company carries on business in India and pays dividend out of profits made in India and taxed in India, the dividend arises directly from a source of income in India and as such dividend income of a non-resident may be deemed to accrue or arise in India. [Caltex (Indiu) Ltd. v. C.I.T. 21 I.T.R. 278].