Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
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Supply of Coursera user licences was held not to be an education service because the applicant only granted access to proprietary digital content and did not impart education, provide faculty, control curriculum, or assume instructional responsibility. Applying the specific-description principle, the supply was classified as a licensing service under Heading 9973, specifically SAC 997331, rather than Heading 9992 or Heading 9984. Because the supply was not an education service, the exemption under Sl. No. 72 of Notification No. 12/2017-Central Tax (Rate) was held inapplicable.
Supply of Coursera user licences was held not to be an education service because the applicant only granted access to proprietary digital content and did not impart education, provide faculty, control curriculum, or assume instructional responsibility. Applying the specific-description principle, the supply was classified as a licensing service under Heading 9973, specifically SAC 997331, rather than Heading 9992 or Heading 9984. Because the supply was not an education service, the exemption under Sl. No. 72 of Notification No. 12/2017-Central Tax (Rate) was held inapplicable.
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