FEES PAID TO A FOREIGN COMPANY FOR RENDERING TESTING AND CERTIFICATION SERVICES CANNOT BE TREATED AS INCOME DEEMED TO ACCRUE OR ARISE IN INDIA UNDER SECTION 9(1)(VII) OF THE INCOME- TAX ACT

It has been held that where services have been rendered outside India and have been utilised for the
purpose of making or earning any income from any source outside India, such payments would fall outside the purview of Section 9(1)(vii) of the Act and will not be deemed to accrue or arise in India.