What did the High Court hold?

The Delhi High Court noted that the issue was covered by its previous judgments in the same assessee's case for earlier assessment years. Therefore, no substantial question of law arose.

The Revenue filed an appeal against an ITAT order concerning Assessment Year 2022-23. The appeal challenged the same issue that had been decided against the Revenue in previous assessment years.

What were the issues?

Whether a substantial question of law arises in the appeal when the issue is covered by previous judgments of the High Court.

CIT vs Coursera Inc | Delhi High Court 2025

$~59 * IN THE HIGH COURT OF DELHI AT NEW DELHI + ITA 671/2025 COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION-1, NEW DELHI .....Appellant Through: Mr. Puneet Rai, SSC, Mr. Ashvini Kr., Mr. Rishabh Nangia, JSCs and Mr Nikhil Jain, Advocate. versus COURSERA INC. .....Respondent Through: None. CORAM: HON'BLE MR. JUSTICE V. KAMESWAR RAO HON'BLE MR. JUSTICE VINOD KUMAR O R D E R % 24.11.2025 CM APPL. 73668/2025 (condn of delay in filing) 1. For the reasons stated in the application, the delay of 10 days in filing the appeal is condoned. 2. The application stands disposed of. CM APPL. 73667/2025 (Exemption) 3. Exemption is allowed, subject to all just exceptions. 4. The application stands disposed of. ITA 671/2025 5. This appeal is filed under Section 260A of the Income Tax Act, 1961 (the Act) lays challenge to the order dated 29.05.2025 passed by the Income Tax Appellate Tribunal (ITAT) in ITA No.1958/Del/2025 which relates to the Assessment Year (AY) 2022-23. 6. Mr Puneet Rai, learned SSC appearing for the Appellant fairly states that the issue involved in this appeal is covered against the appellant /Revenue and in favour respondent/Assessee in terms of the judgment dated This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 28/11/2025 at 15:05:30

19.05.2025 in ITA 157/2025 and ITA 158/2025 passed by this Court in the case of respondent herein relating to AYs 2020-21 and 2021-22 captioned Commissioner of Income Tax, International Taxation)-1 New Delhi v. Coursera Inc, wherein identical issue arose for consideration were dismissed. 7. If that be so, for parity of reasons, as no substantial question of law arises in this appeal, the same is dismissed. V. KAMESWAR RAO, J VINOD KUMAR, J NOVEMBER 24, 2025 M This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 28/11/2025 at 15:05:30

COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION-1, NEW DELHI vs. COURSERA INC.

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