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International TaxArticle·3 April 2026

Online Platform Not FTS

By J the App

Executive Summary


In a decisive affirmation of international tax principles, the Supreme Court has declined to interfere with the Delhi High Court ruling holding that revenues earned by Coursera Inc. from its online learning platform are not taxable in India as Fees for Technical Services or Fees for Included Services. 

The ruling reinforces that mere provision of a digital platform, even with customization and user support, does not meet the “make available” threshold under the India–US DTAA.


In a decisive affirmation of international tax principles, the Supreme Court has declined to interfere with the Delhi High Court ruling holding that revenues earned by Cour...

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