<h1>Agent collecting foreign exam fees not creating PE; fees not taxable in India under DTAA Article 7(1)</h1> An Indian education-services company acting as agent for foreign non-profit professional bodies collected examination fees in India and remitted them abroad; the Authority for Advance Rulings held the company was not a dependent agent nor did it create a permanent establishment for the foreign bodies in India, and payments of examination fees to those foreign entities are not taxable in India under the relevant DTAA provisions (paragraph 1 of Article 7). Consequently no tax is payable in India on those receipts and the Indian agent is not required to deduct tax at source.