S. 28(iv) : Business income – Value of any benefit or perquisites – Converted in to money or not – No benefit or perquisite is chargeable to tax under section 28(iv) for assets received from AEs on a returnable basis- Independent personal services – Training expenses paid to non-resident fell under Article 14 of the DTAA and not subject to TDS- DTAA -India -Singapore . [ Art. 14 ]