Conditions for earning a source of income outside india

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Karkuvel (Querist)

15 February 2019 As per section 9(1)(vii)(b) if the service is provided outside India for earning a income outside India.

Therefore to take that position both the twin conditions should be satisfied
(a) it should be rendered outside India
(b) it should be for earning a source of income outside India

Suppose if the Seller in India Exports goods to Europe. Indian Exporter stores goods in Warehouse to sell the same to Customer and paying rental charges and sorting , Inspection charges to the warehouse service provider.
Whether TDS on Sec 195 attracted for the above case?

Bhaskaran Chackrapani Warrier

Bhaskaran Chackrapani Warrier (Expert)

16 February 2019 195 is not attracted since no services are rendered in India nor payments were
made to foreign parties in India.

Karkuvel

Karkuvel (Querist)

16 February 2019 Thanks for your reply sir. But recently i heard that the recent notification stated that Utilization of services is irrelevant for determining the taxable value under section can u clarify in detail sir

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