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Income deemed to accrue or arise in India - “If Fees for Technical Services is payable by” - Section 9(1)(vii)

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....sident, except of the following * Where it is payable in respect of any right, property or information used or services utilised for the purposes of a business or profession carried on by such person outside India or * For the purposes of making or earning any income from any source outside India]; or * a person who is a non-resident, for the purpose of * Where it is payable in respect o....