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of HC affirmed ITAT's ruling that receipts from a global online learning platform providing courses and degrees do not constitute fees for technical services (FTS) or fees for included services (FIS) under Section 9(1)(vii) and Indo-US DTAA. The court found no perversity in ITAT's factual determination that the services rendered did not involve technical elements or included services, thus rendering the income non-taxable. The HC concluded no substantial legal question emerged, effectively upholding the assessee's tax treatment of the online platform's revenue.
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