Payment to train resources to provide pre & post sale services is FTS

Sunsmart Technologies Pvt. Ltd Vs ACIT (ITAT Chennai) As per Explanation-2 to Sec.9(1)(vii) of the Act, FTS means any consideration (including in lump sum consideration) for the rendering of any managerial, technical or consultancy services, but does not include consideration for any construction, assembling, mining or like project undertaken by the recipient or consideration which would be income of the recipient chargeable under the head ‘salaries’. Further, as per Explanation-2 to Sec.9(2) of the Act, income of a non-resident shall be deemed to accrue or arise in India under Clause (v) ...