Clarification on withholding tax u/s 195: Exam fees by educational institutions exempt under DTAA teaching provisions.

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....Withholding tax u/s 195 - foreign remittances - payment of examination fee collected from the students - The expression ‘teaching in or by educational institution’ cannot be confined to the activity of imparting the instructions alone, in a broader sense, teaching includes not only the imparting the instructions but also the verification of the extent of perception of such instruction by the pupil and thereby includes the activity of examinations also. In this sense, this particular activity falls in the ambit of the exemption clause in the DTAAs which exempt the amounts paid for teaching in or by the educational institutions. - AT....