Section 195

[CA Rachit Agarwal]

Company 'A' is a resident assessess. 'A' export some material to other country. Material is subject to analysis by a non resident of the country to which it exports. Company 'A' makes the payment for analysis charges to non-resident.

1. Whether the analysis income is chargeable to income tax in India?

Analysis is Professional/Technical Services.

[Surender Gupta]

Please see your previous queries: Issue Id: - 2267 and Issue Id: - 2269

You must provide more details and provide your views and opinion on this issue.

[DEV KUMAR KOTHARI]

Dear Rachit,

Do not take risk of getting wrong views or opinion by giving incomplete facts and refraining to give your own analysis- after all you are also a CA

AI Summary

Taxability of technical service fees: whether payments to a non-resident for analysis of exported material attract Indian income tax. Whether payments by an Indian resident company to a non-resident for analysis of exported goods are chargeable to Indian income tax is the central issue; the payment is characterised as for professional/technical services, but respondents requested further factual details and the inquirer's own analysis before any conclusion on taxability can be given.