https://www.taxtmi.com/caselaws?id=237565 Payments to a Singapore entity for programme partnership services were treated as technically characterised under domestic law, but the India-Singapore tax treaty prevailed as the more beneficial provision. The teaching-related services fell within the treaty exclusion for teaching in or by educational institutions under Article 12(5)(c), so the receipts were not taxable as fees for technical services under the treaty. On the facts, the Singapore entity also did not have a permanent establishment in India in relation to telepresence teaching. As a result, the receipts were not chargeable to tax in India and no withholding obligation arose on the payments. en-us Fri, 20 Sep 2013 00:00:00 +0530 Tue, 01 Oct 2013 06:50:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=237565 Payments to a Singapore entity for programme partnership services were treated as technically characterised under domestic law, but the India-Singapore tax treaty prevailed as the more beneficial provision. The teaching-related services fell within the treaty exclusion for teaching in or by educational institutions under Article 12(5)(c), so the receipts were not taxable as fees for technical services under the treaty. On the facts, the Singapore entity also did not have a permanent establishment in India in relation to telepresence teaching. As a result, the receipts were not chargeable to tax in India and no withholding obligation arose on the payments. Case-Laws Income Tax Fri, 20 Sep 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=237565