| (a) | - | in the case of any assessee- |
| (i) | - | any interest (not being interest on a loan issued for public subscription before the 1st day of April, 1938), royalty, fees for technical services or other sum chargeable under this Act, which is payable,- |
| (A) | - | outside India; or |
| (B) | - | Google Play store
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