Source for making or earning income of payer of FTS outside India is not taxable in India

HCL Singapore PTE. Ltd Vs ACIT (ITAT Delhi)

ITAT Delhi held that as conditions prescribed in exception to section 9(1)(vii)(b) stand fulfilled, it cannot be taxed as FTS. Further, the source for making or earning any income of the payer of fee for technical services, in the present case, is outside India, and therefore not taxable in India.

Facts- The assessee is a tax resident of Singapore engaged in the business of providing Information Technology (IT) and Information Te

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