https://www.taxtmi.com/caselaws?id=33617 Composite payments to a U.S. educational entity were examined under Article 12 of the India-USA treaty to determine whether fees for seminars, workshops, telemedicine, e-learning, faculty exchanges and related intellectual property elements were taxable as included services or excluded as teaching in or by educational institutions. Services substantially connected with educational programmes could fall within the teaching exclusion, but the payments were bundled and not separately attributable to excluded teaching services alone. As a result, the payer could not claim that no tax was deductible at source on the entire amount and had to seek determination of the chargeable portion before deducting tax. en-us Fri, 29 May 2009 00:00:00 +0530 Sat, 30 May 2009 00:00:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=33617 Composite payments to a U.S. educational entity were examined under Article 12 of the India-USA treaty to determine whether fees for seminars, workshops, telemedicine, e-learning, faculty exchanges and related intellectual property elements were taxable as included services or excluded as teaching in or by educational institutions. Services substantially connected with educational programmes could fall within the teaching exclusion, but the payments were bundled and not separately attributable to excluded teaching services alone. As a result, the payer could not claim that no tax was deductible at source on the entire amount and had to seek determination of the chargeable portion before deducting tax. Case-Laws Income Tax Fri, 29 May 2009 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=33617