https://www.taxtmi.com/caselaws?id=757415 Access to an online learning platform was analysed under Article 12(4) of the India-USA treaty, and the receipts were treated as not constituting fees for included services because the assessee only facilitated platform access, did not create the course content, conduct examinations, or render technical services, and did not make available any technical knowledge, skill, know-how, or process to the customer. The commentary also notes that an assessment order cannot properly stand where Dispute Resolution Panel directions requiring factual verification and a speaking order are not meaningfully implemented under section 144C. en-us Wed, 21 Aug 2024 00:00:00 +0530 Fri, 23 Aug 2024 15:52:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=757415 Access to an online learning platform was analysed under Article 12(4) of the India-USA treaty, and the receipts were treated as not constituting fees for included services because the assessee only facilitated platform access, did not create the course content, conduct examinations, or render technical services, and did not make available any technical knowledge, skill, know-how, or process to the customer. The commentary also notes that an assessment order cannot properly stand where Dispute Resolution Panel directions requiring factual verification and a speaking order are not meaningfully implemented under section 144C. Case-Laws Income Tax Wed, 21 Aug 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=757415