Income deemed to accrue or arise in India - “If Fees for Technical Services is payable by” - Section 9(1)(vii) - International Taxation - Income Tax

Income deemed to accrue or arise in India - If Fees for Technical Services is payable by - Section 9(1)(vii) Income by way of royalty payable by- the Government; or a person who is a resident, except of the following Where it is payable in respect of any right, property or information used or services utilised for the purposes of a business or profession carried on by such person outside India or For the purposes of making or earning any income from any source outside India]; or a person who is a non-resident, for the purpose of Where it is payable in respect of any right, property or information used or services utilised for the purposes of a business or profession carried on by such person in India or For the purposes of making or earning any income from any source in India. Notes:- FTS means Any consideration (including any lumpsum consideration) for the rendering of any managerial, technical or consultancy services (including providing the services of technical or other personnel). However, it does not include consideration for any construction, assembly, mining or like project undertaken by the recipient or consideration which would be income of the recipient chargeable under the head Salaries . Explanation to Section 9 , where income is deemed to accrue or arise in India under section 9(1)(v), (vi) or (vii), such income shall be included in total income of non-resident regardless of and even if such services are rendered outside India.