The High Court held that GST ITC reversal during inspection may not be voluntary and allowed revival of proceedings after setting aside closure order.

The counsel for the petitioner submitted that authorities have adjudicated on the basis of inputs received from CBDT, taking note of the declaration in the income tax returns.

The Court condoned the delay in filing but found no reason to interfere with the High Court’s factual findings, which held that Coursera’s services did not “make available” technical knowledge under Article 12(4)(b) of the India-US DTAA.