Mayur Khetshi Nisar (Practice) (139 Points)
08 June 2010Non 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
sunil
(article)
(47 Points)
Replied 08 June 2010
when non resident receives income out side india not considered as deemed to accrue arise in india and accordingly not taxable
bhavik mehta
(C.A.)
(526 Points)
Replied 08 June 2010
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.
Shudhanshu Agrawal
(Business)
(2570 Points)
Replied 08 June 2010
| Originally posted by : Mayur Khetshi Nisar | ||
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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 |
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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
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