Chartered Accountant
194 Points
Joined November 2011
According to Section 9(1)(i), any income, directly or indirectly, through of from a property, asset or source of income in India is deemed to accrue and arise in India.
Under section 195, any other sum chargeable to Income Tax in India, not being salaries would require the deduction of tax at source. Deduction under section 195, is to be made by all persons (Resident or Non Resident), while the payee/deductee has to be a Non-Resident.
Therefore, if section 9 is read with section 195, I believe the liability to deduct tax at source exists.