Development agreements require legal possession or effective enjoyment for capital gains transfer; permissive possession and deferred consideration de...
Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
Mutual fund maturity rules require proper rollover, redemption, disclosure, and due diligence; investor gains cannot excuse regulatory breaches or pen...
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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