https://www.taxtmi.com/caselaws?id=3823 Examination fees collected in India on behalf of foreign organisations were characterised as business income, but they were not taxable in India under the applicable treaty because the foreign recipients had no permanent establishment or dependent agent in India. In the absence of a permanent establishment, their business profits were taxable only in the State of residence, so the remittances fell outside India's taxing charge. As the sums were not chargeable to tax, the applicant had no statutory obligation to deduct tax at source on the remittances. en-us Wed, 30 Apr 2008 00:00:00 +0530 Mon, 25 Aug 2008 15:57:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=3823 Examination fees collected in India on behalf of foreign organisations were characterised as business income, but they were not taxable in India under the applicable treaty because the foreign recipients had no permanent establishment or dependent agent in India. In the absence of a permanent establishment, their business profits were taxable only in the State of residence, so the remittances fell outside India's taxing charge. As the sums were not chargeable to tax, the applicant had no statutory obligation to deduct tax at source on the remittances. Case-Laws Income Tax Wed, 30 Apr 2008 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=3823