S. 9(1)(vii):Income deemed to accrue or arise in India – Fees for technical services -Technical services do not include construction, assembly and design — Dominant purpose of contract was supply of passenger rolling stock —Amount received under contract could not be deemed to accrue or arise in India [ S. 194J, 201(IA) ]
CIT v .Bangalore Metro Rail Corporation Ltd. (2022)449 ITR 431 288 Taxman 539 (Karn)( HC)