https://www.taxtmi.com/caselaws?id=65327 Payments by a resident assessee to a foreign collaborator for consultancy, engineering and validation services were treated as fees for technical services deemed to accrue or arise in India under section 9(1)(vii)(b) because the services were used in an Indian business. The statutory exception applies only where the services are utilised in a business or profession carried on outside India, or for earning income from a source outside India; export activity alone does not make the source foreign. The services were also not construction, assembly, mining or a like project within Explanation 2. Accordingly, tax was deductible at source. en-us Wed, 19 Jun 2002 00:00:00 +0530 Tue, 15 Feb 2011 10:21:22 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=65327 Payments by a resident assessee to a foreign collaborator for consultancy, engineering and validation services were treated as fees for technical services deemed to accrue or arise in India under section 9(1)(vii)(b) because the services were used in an Indian business. The statutory exception applies only where the services are utilised in a business or profession carried on outside India, or for earning income from a source outside India; export activity alone does not make the source foreign. The services were also not construction, assembly, mining or a like project within Explanation 2. Accordingly, tax was deductible at source. Case-Laws Income Tax Wed, 19 Jun 2002 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=65327