AAR on taxability of payments made by applicant to a British company for rendering telecom services in India

RELEVANT PARAGRAPH 9. (1) The following incomes shall be deemed to accrue or arise in India :— (i) to (v) xx xx xx xx xx xx xx xx xx (vi) income by way of royalty payable by— (a) the Government ; or (b) a person who is a resident, except where the royalty is payable in respect of any right, property or information used or services utilized for the purposes of a business or profession carried on by such person outside India or for the purposes of making or earning any income from any source outside India ; or (c) a person who is a non-resident, where the royalty is payable ...