<h1>AAR Denies Educational Trust's Application on Tax Deduction for Payments to US Institution Under DTAA Article 12.</h1> The Authority for Advance Ruling (AAR) rejected an application by an educational trust seeking a ruling on tax deduction obligations under the Double Taxation Avoidance Agreement (DTAA) between India and the USA. The trust questioned whether it needed to deduct tax on payments to a US-based institution, Harvard Medical International (HMI), for services rendered, arguing these payments should be exempt under Article 12, paragraph 5(c) of the DTAA. The AAR found insufficient clarity on the nature of services and payments, advising the trust to seek further determination from tax authorities to ascertain the taxable portion of the payments.