https://www.taxtmi.com/caselaws?id=795447 The text concerns whether income earned by a global online learning platform offering courses and degrees through universities and companies accrues in India. It raises the tax characterisation of payments as fees for technical services or fees for included services under the India-US tax treaty, with particular focus on whether services satisfy the treaty's "make available" requirement. The text identifies the scope of that requirement as the central legal question in determining treaty-based taxability of online education-platform income in India. en-us Mon, 20 Jul 2026 00:00:00 +0530 Wed, 22 Jul 2026 13:05:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=795447 The text concerns whether income earned by a global online learning platform offering courses and degrees through universities and companies accrues in India. It raises the tax characterisation of payments as fees for technical services or fees for included services under the India-US tax treaty, with particular focus on whether services satisfy the treaty's "make available" requirement. The text identifies the scope of that requirement as the central legal question in determining treaty-based taxability of online education-platform income in India. Case-Laws Income Tax Mon, 20 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=795447