Fees for technical services deemed to accrue in India under domestic law, with treaty exclusions for professional services. Income deemed to accrue or arise in India includes fees for technical services payable by the Government, by a resident in specified cases, and by a non-resident where the services or related rights, property or information are used in India or for income from India. Fees for technical services means consideration for managerial, technical or consultancy services, including technical personnel, but excludes construction, assembly, mining or similar projects and salary income. Such income is included in the total income of a non-resident even if the services are rendered outside India.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Fees for technical services deemed to accrue in India under domestic law, with treaty exclusions for professional services.
Income deemed to accrue or arise in India includes fees for technical services payable by the Government, by a resident in specified cases, and by a non-resident where the services or related rights, property or information are used in India or for income from India. Fees for technical services means consideration for managerial, technical or consultancy services, including technical personnel, but excludes construction, assembly, mining or similar projects and salary income. Such income is included in the total income of a non-resident even if the services are rendered outside India.
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