https://www.taxtmi.com/caselaws?id=754530 Remittance of examination fees to a foreign university was not chargeable to tax in India because the affiliation arrangement did not establish a permanent establishment, fixed place of business, supervision, control, or principal-agent relationship, and the payment did not make available technical knowledge, skill, or know-how. The amount was therefore not fees for technical services under the treaty, so no tax was deductible at source. On that basis, disallowance under section 40(a)(ia) was not sustainable. en-us Fri, 21 Jun 2024 00:00:00 +0530 Tue, 25 Jun 2024 09:56:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=754530 Remittance of examination fees to a foreign university was not chargeable to tax in India because the affiliation arrangement did not establish a permanent establishment, fixed place of business, supervision, control, or principal-agent relationship, and the payment did not make available technical knowledge, skill, or know-how. The amount was therefore not fees for technical services under the treaty, so no tax was deductible at source. On that basis, disallowance under section 40(a)(ia) was not sustainable. Case-Laws Income Tax Fri, 21 Jun 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=754530