Fees for Technical Services taxed in India when payable by Indian residents or for services used to earn India sourced income. Payments characterised as Fees for Technical Services or royalty are deemed to accrue in India when payable by the Government or residents (unless used for business or income earning outside India) or when payable by non residents where the rights, property, information or services are used for business in India or for earning income in India. FTS includes consideration for managerial, technical or consultancy services, excluding construction/assembly/mining projects and amounts chargeable as salaries; deemed income is includible in a non resident's total income even if 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 taxed in India when payable by Indian residents or for services used to earn India sourced income.
Payments characterised as Fees for Technical Services or royalty are deemed to accrue in India when payable by the Government or residents (unless used for business or income earning outside India) or when payable by non residents where the rights, property, information or services are used for business in India or for earning income in India. FTS includes consideration for managerial, technical or consultancy services, excluding construction/assembly/mining projects and amounts chargeable as salaries; deemed income is includible in a non resident's total income even if services are rendered outside India.
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