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HC affirmed ITAT's ruling that receipts from a global online ...


Online Learning Platform's Global Course Revenue Not Taxable as Technical or Included Services Under Section 9(1)(vii)

May 29, 2025

Case Laws     Income Tax     HC

HC affirmed ITAT's ruling that receipts from a global online learning platform providing courses and degrees do not constitute fees for technical services (FTS) or fees for included services (FIS) under Section 9(1)(vii) and Indo-US DTAA. The court found no perversity in ITAT's factual determination that the services rendered did not involve technical elements or included services, thus rendering the income non-taxable. The HC concluded no substantial legal question emerged, effectively upholding the assessee's tax treatment of the online platform's revenue.

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