Assessee, a US-based company, operated a global online learning platform providing online courses and degrees from leading universities and companies. Assessing Officer taxed receipts from the provision of said services as fees for technical services (FTS) within the meaning of section 9(1)(vii) and fees for included services (FIS) within the meaning of paragraph 4 of Article 12 of the India-USA DTAA. High Court held that the assessee merely provided access to the contents of universities/companies through platform on receipt of fees and Assessing Officer had not brought on record any material to establish fact that assessee provided technical services through its online platform and further make available condition was not satisfied-High Court held also held that since services provided by assessee did not include any element of included services, receipts of assessee could not be taxed as FTS or FIS under provisions of Act as well as DTAA. SLP of revenue dismissed.  (AY. 2020-21)