Determine the taxability of the income under the below mentioned independent cases with respect to the provision of the Income Tax Act, 1961 for the assessment year 2023-24: EFG Ltd., a USA based company, received ₹20 la

As per Section 9(1)(vii)(c) of the Income Tax Act, 1961, income by way of fees for technical services payable by a person who is a resident, where the services are utilized for the purposes of a business or profession carried on by him outside India or for the purposes of making or earning any income from any source outside India, shall not be deemed to accrue or arise in India. In this case, EFG Ltd., a USA-based company, received ₹20 lakh from an Indian company for conducting a feasibility study. The study is in relation to a new business unit to be established in Japan, which is outside India. Therefore, the income from conducting the feasibility study in relation to the new business unit to be established in Japan shall not be taxable as it is for the business outside India. [Section 9(1)(vii)(c)]