training fee paid to a non resident co -tds provisions

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M V S N SHARMA (Querist)
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15 February 2011 A foreign company, which started a JV in India is going to train the employees of the JV in the foreign country on chargeable basis.

My question is can the income be treated as income accrued in India because of the business connection or is it exempt under section 9?

Thanks & Regards

M V S N Sharma

CA. Anuj Gupta

CA. Anuj Gupta (Expert)
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16 February 2011 The answer shall lie in the ultimate usage of the services of the employees after training.
If the answer is India then the income is taxable in India.