https://www.taxtmi.com/caselaws?id=789130 Receipts from a global online learning platform's course and degree services were examined for taxability as fees for technical services under Section 9(1)(vii) and fees for included services under Article 12 of the Indo-US DTAA, with the core issue being whether the services satisfied the "make available" requirement. The ITAT's view, as upheld by the High Court, was that the services did not contain any element of included services and were therefore not taxable as FIS under the treaty. The Supreme Court declined to interfere in Special Leave Petition proceedings, noting that the finding rested on factual assessment of the services rendered and was not shown to be perverse. en-us Wed, 01 Apr 2026 00:00:00 +0530 Fri, 03 Apr 2026 08:49:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=789130 Receipts from a global online learning platform's course and degree services were examined for taxability as fees for technical services under Section 9(1)(vii) and fees for included services under Article 12 of the Indo-US DTAA, with the core issue being whether the services satisfied the "make available" requirement. The ITAT's view, as upheld by the High Court, was that the services did not contain any element of included services and were therefore not taxable as FIS under the treaty. The Supreme Court declined to interfere in Special Leave Petition proceedings, noting that the finding rested on factual assessment of the services rendered and was not shown to be perverse. Case-Laws Income Tax Wed, 01 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=789130