Assessee paid a certain sum to foreign agents for recruitment of international students to various courses in India. Tribunal held that the nature of services rendered by these foreign agents was simply marketing services, introducing foreign students to take admission to university and, therefore, remittances made by the assessee outside India to these agents could not be deemed to accrue or arise in India. Not liable to deduct tax at source.  Payment on account of the evaluation of PhD thesis could not be treated as fees for technical service. (AY. 2011-12 to 2016-17)