‘Fees for Technical Services’ mean any consideration (including any lump sum consideration) for rendering of any managerial, technical or consultancy services (including the provision of services of technical or other personnel) but does not include consideration for any construction, assembly, mining or like project undertaken by the recipient or consideration which would be income of the recipient chargeable under the head ‘Salaries’. ‘Fees for technical services^‘ is deemed to accrue or arise in India

• if the income is payable by the Government of India.
• if the income is received from person resident in India and the payment is relatable to any other source of income.
• if the income is received from person non-resident in India and the payment is relatable to a business or profession in India or any other source carried by the payer in India.

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