https://www.taxtmi.com/caselaws?id=771950 Receipts from an online education platform were held not taxable in India as fees for included services under Article 12(4) of the India-US DTAA because the services did not satisfy the make available condition. The Tribunal followed its earlier ruling in the assessee's own case for prior years, which had already treated the receipts as neither royalty nor fees for included services, and noted that the jurisdictional High Court had upheld that position. Applying consistency and binding precedent on identical facts, the addition made on this account was deleted. en-us Thu, 29 May 2025 00:00:00 +0530 Fri, 30 May 2025 15:32:50 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=771950 Receipts from an online education platform were held not taxable in India as fees for included services under Article 12(4) of the India-US DTAA because the services did not satisfy the make available condition. The Tribunal followed its earlier ruling in the assessee's own case for prior years, which had already treated the receipts as neither royalty nor fees for included services, and noted that the jurisdictional High Court had upheld that position. Applying consistency and binding precedent on identical facts, the addition made on this account was deleted. Case-Laws Income Tax Thu, 29 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=771950