Where assessee had entered into agreement with UK based university for providing certain technical services for which it had agreed to bear Indian taxes, liability of assessee to deduct TDS under India-UK DTAA from payments made to UK University was to be computed on gross amount of fees paid to University

The Honorable High Court of Madras in the instant case has held that TDS on payments made to non-residents for technical services has to be deducted on the gross amount including the tax liability undertaken by the assessee.