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

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.... by way of royalty payable by- • the Government; or • a person who is a resident, 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 ....

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....ient chargeable under the head "Salaries". • Explanation to Section 9, where income is deemed to accrue or arise in India under section 9(1)(v), (vi) or (vii), such income shall be included in total income of non-resident regardless of and even if such services are rendered outside India. Important Case Law • The Tribunal held that the receipts earned by the assessee, ....

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....ection extends only to the extent the partnership income is subject to tax in the UK as income of a resident, either in its own hands or in the hands of its partners. Article 13 of the India-UK DTAA excludes payments to individuals or partnership firms for professional services covered under Article 15, including services rendered by lawyers, from the scope of fees for technical services.&nbs....