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RESIDENTIAL STATUS
CA Abhishek Mittal
CA Sakshi Mittal
1
Topic: Residential Status
Content Section
Scope of total income/incidence of tax 5
Residence in India 6
Rules for determining the residential status of an Individual 6(1), 6(6)(a)
Rules for determining the residential status of an Hindu Undivided
Family/Firm/ Association of Person/Body of Individual
6(2), 6(6)(b)
Rules for determining the residential status of a Company 6(3)
Rules for determining the residential status of any other person 6(4)
Incomes deemed to be received 7
Dividend Income 8
Income deemed to accrue or arise in India 9
‘Person’ defined 2(31)
Scope of Total Income / Incidence of Tax [Section 5]:
Scope of total income is according to the residential status of the assessee.
Resident and Ordinarily Resident (ROR) [Section 5(1)]
The total income of any previous year of a person who is a resident and ordinarily
resident includes all income from whatever source derived, which -
is received or is deemed to be received in India in such year by such person.
accrues or arises or is deemed to accrue or arise to him in India during such year.
accrues or arises to him outside India during such year.
Resident but Not Ordinarily Resident (R+NOR) [Section 5(1)]
The total income of any previous year of a person who is a resident and not ordinarily
resident includes the following incomes -
income which is received or is deemed to be received in India in such year by such
person or
income which accrues or arises or is deemed to accrue or arise to him in India during
such year or
income which accrues or arises to him outside India, if it is derived from a business
controlled in or a profession set up in India.
Non-Resident (NR) [Section 5(2)]
The total income of any previous year of a person who is non-resident includes all income
from whatever source derived which –
is received or is deemed to be received in India in such year by such person or
accrues or arises or is deemed to accrue or arise to him in India during such year.
Tax Incidence/Scope of Total Income
Type of Income
Residential Status
ROR NOR NR
1. Income received in India Taxable Taxable Taxable
2. Income deemed to be received in India Taxable Taxable Taxable
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3. Income which accrues or arises or is deemed to
accrue or arise to the assessee in India in the previous
year
Taxable Taxable Taxable
4. Income which accrues or arises to the assessee
outside India and is also received outside India
Taxable Not Taxable Not
Taxable
5. Income which accrues or arises to the assessee
outside India and is also received outside India but it
is either from a business controlled from India or from
a profession set up in India
Taxable Taxable Not
Taxable
6. Past untaxed income (earned and received abroad)
remitted to India in previous year
Not Taxable Not Taxable Not
Taxable
Received in India means first receipt in India. If an income is received first outside India
and then subsequently remitted to India, it shall be treated as received outside India
i.e. remittance of fund is not taxable in India.
Past untaxed profits shall not be considered to be income of the current year in any case.
Example: Mr. R has one house in UK and rent has been received directly in India. It will
be considered to be income received in India and it is chargeable to tax in case of all the
three status, but if Mr. R has one bank account with Bank of UK, New York and rent has
been deposited in that account and subsequently the bank has transferred the amount
to Mr. R in India, it will be considered to be income received outside India, because
income has already been received outside India and subsequently it was remitted to
India.
Similarly, if Mr. R has income from agriculture in Nepal and it was deposited in the
branch of an Indian bank in Nepal, subsequently the amount was remitted in India, it
will be considered to be income received outside India.
Example: Mr. K earns the following income during the financial year 2015-16:
1. Income from house property in London, received in India 60,000
2. Profits from business in Japan and managed from there (received in Japan) 9,00,000
3. Dividend from foreign company, received in India 30,000
4. Dividend from Indian company, received in England 50,000
5. Profits from business in Kenya, controlled from India, Profits received in Kenya 3,00,000
6. Profits from business in Delhi, managed from Japan 7,00,000
7. Capital gains on transfer of shares of Indian companies, sold in USA and gains were
received there 2,00,000
8. Pension from former employer in India, received in Japan 50,000
9. Profits from business in Pakistan, deposited in bank there 20,000
10. Profits on sale of asset in India but received in London 8,000
11. Past untaxed profits of UK business of 2014-15 brought into India in 2015-16 90,000
12. Interest on Government securities accrued in India but received in Paris 80,000
13. Interest on USA Government securities, received in India 20,000
14. Salary earned in Bombay, but received in UK 60,000
15. Income from property in Paris, received there 1,00,000
(Presume all the above incomes are computed incomes)
Determine the gross total income of Mr. K if he is (i) resident and ordinarily resident,
resident but not ordinarily resident, non-resident in India during the FY 2015-16
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SN Particulars of Transaction ROR NOR NR
1 Income received in India 60,000 60,000 60,000
2 Income accruing/arising and received
outside India
9,00,000 - -
3 Income received in India 30,000 30,000 30,000
4 Income accruing in India but exempt under
section 10(34)
- - -
5 Income accruing/arising and received outside
India, but business controlled from India
3,00,000 3,00,000 -
6 Income accruing/arising in India 7,00,000 7,00,000 7,00,000
7 Income accruing/arising in India 2,00,00 2,00,00 2,00,00
8 Income accruing/arising in India 50,000 50,000 50,000
9 Income accruing/arising outside India and
received outside India
20,000 - -
10 Income accruing/arising in India 8,000 8,000 8,000
11 Past untaxed profits - - -
12 Income accruing/arising in India 80,000 80,000 80,000
13 Income received in India 20,000 20,000 20,000
14 Income accruing/arising in India 60,000 60,000 60,000
15 Income accruing/arising outside India and
received outside India
1,00,000 - -
Total Income 25,28,000 15,08,000 12,08,000
Residence in India/Determination of Residential Status [Section 6]:
Whether a particular income shall be taxed in India or not, will depend on the residential
status of the person and the type of income i.e. in order to determine tax incidence as per
section 5, there is a need to determine the residential status and also the type of income.
Residential status in fact explains the relationship of the assessee with the country and
helps in determining the scope of the total income.
Residential status of an Individual [Section 6(1)]:
Residential status of an “assessee” is determined on year to year basis and it may be
differ from year to year. An individual is said to be resident in India in any previous year,
if he complies with at least one of the following two basic conditions:
He is in India for a period amounting in all to 182 days or more in the relevant
previous year or
He is in India for a period amounting in all to 60 days or more during the relevant
previous year and also for 365 days or more during 4 years immediately preceding
the relevant previous year.
It is not compulsory that stay should be continuous rather total stay during the year
should be 182 days or 60 days as the case may be.
If an individual do not comply with any of the basic conditions mentioned above, he
will be considered to be non-resident as per section 2(30).
The day of departure as well as arrival shall be considered to be the day of stay in
India.
Residential status is determined for every year separately.
Example: Mr. R came to India for first time on 01.10.2015 and left India on 31.03.2016,
in this case, his stay in India shall be considered to be of 182 days and he will be
considered to be resident in India. [31 + 30 + 31 + 31 + 28 + 31 = 182]
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Special Category: This Condition (i.e. he is in India for a period amounting in all to 60
days or more during the relevant previous year and also for 365 days or more during 4
years immediately preceding the relevant previous year) is not applicable in the following
cases. In these below mentioned cases only first condition i.e. he is in India for a period
amounting in all to 182 days or more in the relevant previous year.
If Indian Citizen leaves India during the previous year for the purpose of employment
outside India or as a member of crew of an Indian Ship.
If Indian citizen or person of Indian origin visits India during the previous year.
Stay in territorial waters: If any person has stayed in Indian territorial waters, it will
be considered to be stay in India. Territorial waters extend upto 12 nautical miles from
the base line on the coast of India and include any bay, gulf, harbour, creek or tidal
river. (1 nautical mile = 1.1515 miles = 1.852 Km.). India includes territorial water of
India.
Employment shall include self-employment i.e. any business or profession. Example Mr.
D, is a citizen of India, and he has left India for first time on 01.09.2015 for taking up
an employment outside India. Mr. D will be covered under special category and his
residential status shall be non-resident.
If any person has any business or profession in India and he has left India in connection
with such business or profession, he will not be covered in special category. Example
Mr. V a citizen of India has one business in India and he has left India in connection with
such business for the first time on 01.09.2015. In this case, his residential status shall
be resident and ordinarily resident.
Person of Indian origin [Explanation to Section 115C(e)]
A person shall be deemed to be of Indian origin if he, or either of his parents or any of
his grand-parents, was born in undivided India before 15th August 1947 and place of
birth is in India, Pakistan or Bangladesh. Grandparents shall include the parents of
mother also.
Meaning of “Resident and Ordinarily Resident” (ROR) and “Resident but Not
Ordinarily Resident” Individual (NOR) [Section 6(6)(a)]
An individual who is resident in India shall be resident and ordinarily resident (ROR) in India
if he satisfies both the following conditions:
He has been resident in India for at least 2 out of 10 previous years immediately
preceding the relevant previous year and
He has been in India for 730 days or more during the 7 previous years immediately
preceding the relevant previous year.
If he does not satisfy any or both of the above conditions, he shall be resident but not
ordinarily resident (R+NOR) in India.
Example: Mr. R and Mrs. R are settled outside India and they came to India on
15.10.2015 on a visit for 7 months. Both of them are Indian citizens. In the earlier years
they were in India as follows:
Year Mr. R Mrs. R
2014 – 2015 235 Days 365 Days
2013 – 2014 330 Days 30 Days
2012 – 2013 Nil 28 Days
2011 – 2012 118 Days 120 Days
Find out the residential status of Mr. R and Mrs. R for the assessment year 2016-17.
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Solution: Both are Non Resident for the assessment year 2016-17 because stay of Mr.
R and Mrs. R in India (17+30+31+31+29+31) = 169 days
Since they are covered in special category they will be resident only if their stay in India
in relevant previous year is 182 days or more, hence they are non-resident.
Example: Brett Lee, an Australian cricketer players visit India for 100 days in every
financial year. This has been his practice for the past 10 years. Find out the residential
status for the assessment year 2016-17.
Solution: Determination of residential status of Mr. Brett Lee for the AY 2016-17:
Checking basic condition:
Period of stay during previous year 2015-16 is 100 days
Period of stay during 4 preceding previous year is 400 days (100 days * 4)
Mr. Lee is in India for a period more than 60 days during the PY and a period of more
than 365 days during the 4 immediately preceding previous years. Therefore, he satisfies
one of basic condition. Hence he is resident for the AY 2016-17.
Checking additional conditions:
Period of stays during 7 preceding previous years = 700 days (100 days *7)
Since the period of stay in India during the past 7 years is less than 730 days, he is not
ordinarily resident during the AY 2016-17.
Hence Mr. Lee is Resident but not ordinarily resident during the AY 2016-17.
Residential Status of Hindu Undivided Family (HUF) [Section 6(2)]
A Hindu Undivided Family is said to be resident in India when during that year control and
management is in India either partly or completely. In other words, it will be non-resident
in India where during that year the control and management of its affairs is situated wholly
outside India.
In case of Hindu Undivided Family, since the control and management of the Hindu
Undivided Family is in the hands of its Karta, hence the place of stay of Karta shall be
considered to be the place of control and management of the Hindu Undivided Family.
Example: Karta of one HUF is in London throughout the year, the HUF shall be considered
to be non-resident. However, if Karta has come to India for a few days and has participated
in control and management of the HUF, it shall be considered to be resident.
Delegation of power - Karta for this purpose shall be considered to be the de-facto
(actual Karta) i.e. if Karta has delegated his powers to any other member, such other
member shall be considered to be the de-facto Karta.
Meaning of “Resident and Ordinarily Resident” and “Resident but Not Ordinarily
Resident” Hindu Undivided Family [Section 6(6)(b)]
An Hindu Undivided Family shall be considered to be resident and ordinarily resident in India
if the Karta of the HUF satisfies both the following conditions:
He (Karta) has been resident in India for at least 2 out of 10 previous years immediately
preceding the relevant previous year and
He (Karta) has been in India for 730 days or more during the 7 previous years
immediately preceding the relevant previous year.
If the Karta of HUF does not satisfy any or both of the above conditions, then HUF shall
be resident but not ordinarily resident in India.
Karta of Hindu Undivided Family is non-resident in his individual capacity but the Hindu
Undivided Family is resident.
Example: One Hindu Undivided Family is being managed partly from Mumbai and partly
from Nepal. Mr. P (a foreign citizen), Karta of Hindu Undivided Family, comes on a visit
to India every year since 1991 in month of April for 105 days.
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Determine residential status of the Hindu Undivided Family and also that of the Karta in
his individual capacity for the assessment year 2016-17.
Solution: For the previous year 2015-16, the control and management of the affairs of
Hindu Undivided Family is being partly managed from India. Hence Hindu Undivided
Family is resident but Mr. P complied with both of the conditions of section 6(6)(b),
hence Hindu Undivided Family is resident and ordinarily resident.
Karta shall be considered to be resident and ordinarily resident because his stay during
7 years is 735 days. Also, he will not be non-resident in nine years out of ten years
preceding the relevant previous year.
Determination of Residential Status of a Firm/ Association of Persons (AOP)/Body of
Individual (BOI) [Section 6(2) and 6(4)]:
A Firm, AOP, BOI is said to be resident in India when during that year control and
management is situated in India either partly or completely. In other words it will be non-
resident in India where during that year the control and management of its affairs is situated
wholly outside India.
Control and management lies at the place where decision regarding the affairs of the firms
are taken.
Example: There is a partnership firm Dheeru Brothers where Mr. Anil Ambani is a working
partner and Mr. Mukesh Ambani is non-working partner. Mr. Anil Ambani is out of India. Mr.
Mukesh Ambani is in India throughout the year. In this case, partnership firm shall be
considered to be non-resident but if Mr. Anil Ambani has come to India for a few days, the
firm shall be considered to be resident. Similarly, if Mr. Anil Ambani is out of India but he
has appointed one manager in India for control and management of the firm, the firm shall
be considered to be resident. Mr. Anil Ambani delegated his power but still he have control
on that person.
Profits received from a partnership firm is exempt in the hands of the partners but if
firm is situated outside India and share of income from such firm is deemed to accrue
or arise in India, then such share of income shall be taxed in the respective partner’s
hand.
Residential Status of Company[Section 6(3)]:
A company is said to be resident in India in any previous year, if –
it is an Indian company or
during that year, the control and management of its affairs i.e. place of effective
management (POEM) is situated wholly in India.
Indian Company is always resident in India.
Company which is incorporated outside India is a Foreign Company. Residential
status of foreign company depends upon place of effective management. Foreign
company is resident in India if control and management of its affairs is situated wholly
in India during relevant previous year i.e. if all the board meetings of the foreign
company is held in India, then it shall be resident, otherwise non-resident.
There is no concept of ROR and NOR in case of person other than Individual and HUF.
Only different treatment for foreign company (entire control in India to be treated as
Resident). HUF, Firm, AOP,BOI, Clubs etc. even if partly controlled from India, shall
become resident.
Example: Wipro Ltd. an Indian company has most of its business outside India.
Determine its residential status – An Indian Company shall always be considered to
be resident in India.
Example: Afcon Infrastructure Ltd. is a Japanese company, but it is being controlled
from India. Determine its residential status for the assessment year 2016-17 -
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Foreign Company shall be resident in India only if its control and management is
wholly in India. Hence, Afcon infrastructure Ltd. is resident company.
Example: Bista Ltd., a foreign company, has made prescribed arrangements for
declaration and payment of dividend within India in accordance with section 123.
Bista Ltd. carries on majority of its operations and decision making activities from
Calcutta and Assam but some part of operational activities and few decisions are
being taken from the place at which registered office of Bista Ltd. is located, i.e.
Dhaka. Determine its residential status for the assessment year 2016-17.
Solution: Bista Ltd. is neither an Indian company nor its control and management
is wholly situated in India. Bista Ltd. is, therefore, non–resident in India for the
assessment year 2016-17.
“Persons” Section 2(31) includes—
Individual,
Hindu Undivided Family,
Company,
Firm,
Association of persons or Body of individuals, whether incorporated or not,
local authority, and
every artificial juridical person, not covered above.
Income received or deemed to be received in India [Section 7]:
Income Received in India: Any income which is received in India is liable to tax in India,
whether the person receiving income is resident or non- resident. ‘Received in India’ means
first receipt.
Income deemed to be received in India: Following incomes shall be deemed to be
received in India even in the absence of actual receipt:
Contribution by employer to recognized provident fund in excess of 12% of salary of
employee
Interest on employee’s and employer’s credited to RPF in excess of 9.5%
Transferred balance from unrecognized PF to RPF
Contribution by Government/Employer to notified pension scheme
Dividend Income [Section 8]
Dividends from Indian company shall always be deemed to accrue or arise in India.
However, as per Sec 10(34), such dividend is exempt in the hands of shareholder except
dividend received under section 2(22)(e). Example: Dividend from Indian Company,
Received in England – Exempt u/s 10(34)
Dividend from a foreign company shall continue to be taxed in the hands of the shareholder.
Example – Dividend from X Ltd, received in India – Fully Taxable
Income deemed to accrue or arise in India [Section 9]:
The following income shall be deemed to accrue or arise in India –
Income from any property, asset or source of income in India
Income from the transfer of any capital asset situated in India
Any income from salary if it is payable for services rendered in India
Salary (not allowances) payable by the government of India to an Indian citizen for
services rendered outside India. However as per section 10(7) allowances and
perquisites are exempt from tax.
Example: Mr. A is citizen of India and is an IFS. He is posted in Indian embassy in USA,
in this case, his salary income shall be accruing/arising in India. (However under section
10(7), allowances and perquisites to such person are exempt from tax)
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A dividend paid by an Indian company outside India. (However, dividends received from
a domestic company shall be exempt from income tax in the hands of the shareholder
under section 10(34), but the domestic company has to pay additional income tax @
15% plus surcharge @ 10% plus education cess @ 2% plus SHEC @ 1% , as per section
115O).
Income by way of interest payable by –
Indian Government or
Resident in India if money is used by the borrower for the purpose of business or
profession or earning any income from any source in India or
Example: A Ltd. an Indian company has taken a loan from an agency in USA and the
amount was utilised in USA. In this case, interest income shall be accruing/arising in
USA.
Non-resident in India if money is used by the borrower for the purpose of business
or profession in India. Example: Interest on money borrowed from outside India Rs.
500,000 by a non-resident for the purpose of business with in India say, at Delhi
Income by way of Royalty payable by –
Indian Government or
Resident or Non Resident in India if services are utilized for the purpose of business
or profession or earning any income from any source in India
Income by way of fees for technical services payable by –
Indian Government or
Resident or Non Resident in India if services are utilized for the purpose of business
or profession or earning any income from any source in India
Fees for Technical Services means any consideration for the rendering of Managerial,
Technical or Consultancy Services
Income from a Business Connection in India –
If any person has business in India as well as outside India, it will be called business
connection and in case of such business, the income of the business deemed to
accrue or arise in India shall be only such part of the income as is reasonably
attributable to the operations carried out in India. If all business activities are not
carried out in India, then only such part of income, as is reasonably attributable to
the operations carried out in India, is taxable.
Examples of business connection includes –
a. Branch office in India,
b. Subsidiary in India,
c. Maintaining Stocks,
d. Agents of non-resident entering into contracts.
Determination of income in the case of non-residents [Rule 10]
In any case in which the Assessing Officer is of opinion that the actual amount of the
income accruing or arising to any non-resident person whether directly or indirectly,
from any business connection in India or from any property in India or from any asset
or source of income in India or from any money lent at interest cannot be definitely
ascertained, the amount of such income for the purposes of assessment to income-tax
may be calculated –
at such percentage of the turnover as the Assessing Officer may consider to be
reasonable, or
on any amount which bears the same proportion to the total profits and gains of
the business of such person, as the receipts so accruing or arising bear to the total
receipts of the business or
in such other manner as the Assessing Officer may deem suitable
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However, in case of Non-resident, there is no Business Connection in India in
the following three cases
Purchase of goods in India for purpose of exports [Explanation 1(b) to Section
9(1)(i)]
Collection of news and views in India for transmission outside India by non-resident
who is engaged in the business of running news agency or of publishing newspapers,
magazines or journals [Explanation 1(c) to Section 9(1)(i)]
Shooting of cinematograph films in India [Explanation 1(d) to Section 9(1)(i)] if
a. In case of individual – he is not a citizen of India
b. In case of Firm – none of the partner is citizen or resident of India
c. In case of company – none of the shareholder is citizen or resident of India
Barendra Prasad Ray v. ITO [1981] 129 ITR 295 (SC): The expression
“business” does not necessarily mean only trade or manufacture rather it will include
profession, vocation and calling. In the context in which the expression ‘business
connection’ is used in section 9(1), there is no warrant for giving a restricted meaning
to it excluding ‘professional’ connection, from its scope.
Example: A had following income during the previous year ended 31st March, 2016:
(1) Salary received in India for three months (being computed income) 25,000
(2) Income from house property in India 18,000
(3) Interest on savings bank deposit in SBI, in India 4,000
(4) Amount brought into India out of the past-untaxed profits 20,500
(5) Income from business in Bangladesh, being controlled from India 12,542
(6) Dividends received in Belgium from French companies, out of which
2,500 were remitted to India 23,150
You are required to compute his gross total income for the assessment year 2016-17, if
he is a resident and ordinarily resident; not ordinarily resident; and non-resident.
Presume all the above income is computed income.
Particulars ROR NOR NR
Salary received in India 25,000 25,000 25,000
Income from house property in India 18,000 18,000 18,000
Interest on saving bank deposit in SBI, in India 4,000 4,000 4,000
Past untaxed profit brought into India - - -
Income from business in Bangladesh, being
controlled from India
12,542 12,542 -
Dividend received in Belgium 23,150 - -
Gross Total Income 82,692 59,542 47,000
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Summary of Residential Status
Section 5 Incidence of Tax
R-OR R-NOR NR
1 Income which accrues
or arise in India.
(Indian Income)
Taxable Taxable Taxable
2 Income which accrues
or arise outside India.
(Foreign Income)
Taxable Not Taxable. However in case of Not Taxable
But if
income is
received in
India then
Taxable
Business Income Professional
Income
Taxable if business
is controlled from
India
Taxable if
profession is set up
in India
Taxable if any income is received in India
Section 6 : Determination of Residential Status
(1) (2) (3) (4) (5) (6)
Individual HUF, Firm,
AOP/BOI
Company Local
Authority/AJP
Individual/HUF
Basic Condition + Additional Condition
Satisfies Do not satisfy Satisfies Do not
satisfy
Resident Non Resident R-OR R-NOR
Section 6(1) & 6(6): Determination of Residential Status of Individual
Section 6(1) Basic Condition
If an individual is present in India
(a) For a period or periods of atleast 182
days in the relevant PY; or
}
Satisfies any one basic
condition
Resident in
India
(b)
For atleast 60 days in the relevant PY
and atleast 365 days in last 4 years
immediately preceding the relevant PY
Do not satisfies any basic
condition
Non Resident
in India
Exceptions – Check only 182 days
(a) If an Indian citizen leaves India for the purpose of employment or leaves India as a
crew member of Indian Ship.
(b) If an Indian Citizen or Person of Indian Origin comes to India on a visit from outside
India.
As per explanation to S 115C (e) A Person is said to be of Indian Origin if he himself or his
Parents / Grandparents are borne in undivided India. Check date of birth should be before
15-8-1947 and place of birth is in India, Pakistan or Bangladesh.
Section 6(6) Additional Condition
(a) Resident in India for atleast 2 years in last 10
years immediately preceding the relevant PY;
and
}
If he satisfies both the Additional
Condition then Residential Status is
R-OR (Resident and Ordinarily
Resident) otherwise R-NOR
(Resident and Not Ordinarily
Resident)
(b) Present in India for atleast 730 days in last 7
years immediately preceding the relevant PY.
Residential Status of Company Control & Mgt. of the affairs of the business
In India Outside India
S 6(3)
Foreign Company Wholly Wholly/Partially
Resident Non-Resident
S 6(3) Indian Company Always resident irrespective of control and
management of the affairs of the company
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Residential Status of Other Person Control & Mgt. of the affairs of the business
In India Outside India
S 6(2) HUF, Firm, AOP/BOI
Wholly/Partially
Wholly S 6(4) Local Authority, AJP
Resident Non-Resident
Section 9(1) – Income deemed to accrue or arise in India
i. Income from “Business Combination”
Business outside India and part
activity of business carried out in India
Also called permanent establishment
or territorial nexus
Exceptions to the business combination
a. All operation not carried out in India
b. Purchase for export
c. Collection of news
d. Shooting of films in India by foreign citizen
Assets, capital asset or property located in India
ii. Services rendered in India by any person.
iii. Services rendered outside India by Indian Citizen. Employer is Govt. of India. However as
per sec 10(7) allowances and perquisites are exempt from tax. Only basic salary is taxable.
iv. Dividend from Indian Company. However it is exempt from tax u/s 10(34)
v. Interest on loan which is used in India If interest, royalty or FTS is payable by
Govt. of India then such income deemed to
accrue or arise in India whether there is
business connection or not.
vi. Royalty from knowledge which is used in India
Vii. Fees for technical services which is used in
India
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