SC Upholds Non-Taxability of Online Platform Income Due to Failure of ‘Make Available’ Test

CIT (International Taxation)-1 Vs Coursera Inc. (Supreme Court of India) The Supreme Court considered a Special Leave Petition filed by the Revenue against the judgment of the Delhi High Court, which had upheld the decision of the Income Tax Appellate Tribunal (ITAT) in favour of the assessee. The Supreme Court condoned the delay but declined to interfere with the High Court’s judgment, thereby dismissing the petition. Before the High Court, the dispute concerned the taxability of receipts earned by a US-based company operating a global online learning platform, for Assessment Year 2020–21...