https://www.taxtmi.com/caselaws?id=8904 A non-resident's technical service fee was treated as income accruing or arising in India where the contract required its personnel to come to India to assist in setting up, supervising and operating the plant and to train Indian staff. The Court applied the settled test of business connection under section 42(1), requiring a real and intimate relation and continuity between the foreign business and the local activity, and held that the services rendered in India formed part of the income-earning activity. On that basis, the fee was not divisible as suggested by the assessee and was taxable in India as Indian-source income through a business connection. en-us Fri, 04 May 1973 00:00:00 +0530 Wed, 17 Jun 2009 10:45:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=8904 A non-resident's technical service fee was treated as income accruing or arising in India where the contract required its personnel to come to India to assist in setting up, supervising and operating the plant and to train Indian staff. The Court applied the settled test of business connection under section 42(1), requiring a real and intimate relation and continuity between the foreign business and the local activity, and held that the services rendered in India formed part of the income-earning activity. On that basis, the fee was not divisible as suggested by the assessee and was taxable in India as Indian-source income through a business connection. Case-Laws Income Tax Fri, 04 May 1973 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=8904