https://www.taxtmi.com/caselaws?id=789130 Receipts from a global online learning platform were considered in relation to accrual of income in India and the scope of the "make available" requirement under the India-US DTAA. The ITAT found, on the factual nature of the services rendered, that the platform's offerings did not contain any element of included services and were therefore not taxable as fees for included services under Article 12. The Delhi HC accepted that conclusion, and the SC dismissed the Special Leave Petition, declining to interfere with the factual findings that the receipts were not chargeable as FIS. en-us Wed, 01 Apr 2026 00:00:00 +0530 Fri, 03 Apr 2026 08:49:31 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=789130 Receipts from a global online learning platform were considered in relation to accrual of income in India and the scope of the "make available" requirement under the India-US DTAA. The ITAT found, on the factual nature of the services rendered, that the platform's offerings did not contain any element of included services and were therefore not taxable as fees for included services under Article 12. The Delhi HC accepted that conclusion, and the SC dismissed the Special Leave Petition, declining to interfere with the factual findings that the receipts were not chargeable as FIS. Case-Laws Income Tax Wed, 01 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=789130