Permanent Establishment and Business Connection: foreign consultancy receipts not attributable where no fixed base or corporate veil piercing establis...
Limitation period commencement and procedural inquiry rules: identity-based limitation upheld; complaints by authorised public servants need not attra...
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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