Case of CIT (International Taxation) vs Coursera Inc, SC Judgement Dated 1st April 2026. The apex court held that income earned by the US based Coursera from its online learning platform is not taxable as Fees for Technical Services (FTS/FIS) in India. The court confirmed that respondent services failed the ‘make available’ test under the India-USA Double Taxation Avoidance Agreement (DTAA).