S. 9(1)(vii):Income deemed to accrue or arise in India-Fees for technical services-Salary-Expatriate employees-Tax deducted at source-Reimbursed by Indian subsidiary on cost-to-cost basis-Reimbursement is not taxable-Not fees for technical services -Not liable for tax deduction at source-DTAA-India-Japan. [S. 192, 195, Art. 12]