(7)(a)Income by way of fees for technical services payable by––(i)the Government;(ii)a resident, except where it is payable in respect of services utilised for—(A) a business or profession carried on by such resident outside India; or(B) making or earning any income by such resident from any source outside India; or(iii)a non-resident, if it is payable in respect of services utilised for—(A) a business or a profession carried on by such non-resident in India; or(B) making or earning any income by such non-resident from any source in India,shall be deemed to accrue or arise in India;(b)in this sub-section, "fees for technical services" means any consideration (including any lump sum consideration) for the rendering of any managerial, technical or consultancy services (including the provision of services of technical or other personnel) but does not include consideration—(i)for any construction, assembly, mining or like project undertaken by the recipient; or(ii)which would be income of the recipient chargeable under the head "Salaries".
