TDS on payments made to a foreign university.

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Hello,
We have a client company which sent its employees to a foreign country to take training in a university established in that country. The foreign university doesnt have any permanent establishment in india. The amount payable by indian co. to the foreign university is $15,000. Is there any tax liability in this case. Is the indian co. liable to deduct income tax (tds) on the payment to be made. Please advise as per law.

Replies (1)
Training fees shall not be considered as a 'fees for technical services' within a meaning of section 9(1)(vii) of the Act and hence, not liable for TDS. Kindly refer the judgement of Lloyds Register Industrial Services (India) Pvt. Ltd. vs. ACIT [ITA No. 940 & 7628/Mum/04].

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