Taxbility of Training Income of Non Residents

when non resident receives income out side india not considered as deemed to accrue arise in india and accordingly not taxable

to the best of my knowledge,

that income is accrued in India only as he came in India & for the providing  training in India he is getting fees for that.so, its accrued in India & so taxable in India, no matter that whether it is received in or outside India.

194-j there is a not liability to deduct tax at source.

Originally posted by : Mayur Khetshi Nisar
	Non Residents came to India to train the employees on Software use.  Billing is in $ and payment is outside India in $. Whether it is income arised in India ? Please support the answer with adequate reasoning.  Thanks & Regards Mayur

 Depending upon the nature of the the payment i.e. salary or technical services it will fall under Section 9 of the Income Tax  Act, 1961