No “Make Available” of Technical Knowledge: Supreme Court Upholds Non-Taxability of Receipts Under India

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No “Make Available” of Technical Knowledge: Supreme Court Upholds Non-Taxability of Receipts Under India–US DTAA

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Published on

27/04/2026

By Mariya Paliwala

No “Make Available” of Technical Knowledge: Supreme Court Upholds Non-Taxability of Receipts Under India–US DTAA

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The Supreme Court of India has dismissed a Special Leave Petition filed by the Income Tax Department, thereby affirming the ruling of the Delhi High Court that receipts earned by Coursera Inc. are not taxable in India as Fees for Included Services (FIS) under the India–US Double Taxation Avoidance Agreement (DTAA). The bench of Justice…

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Mariya Paliwala https://www.jurishour.in/

Mariya is the Senior Editor at Juris Hour. She has 7+ years of experience on covering tax litigation stories from the Supreme Court, High Courts and various tribunals including CESTAT, ITAT, NCLAT, NCLT, etc. Mariya graduated from MLSU Law College, Udaipur (Raj.) with B.A.LL.B. and also holds an LL.M. She started her career as a freelance tax reporter in the leading online legal news companies.

No “Make Available” of Technical Knowledge: Supreme Court Upholds Non-Taxability of Receipts Under India–US DTAA

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