(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;