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of <h1>Supreme Court India dismisses special leave petitions, delays condoned, pending applications disposed</h1> <h3>COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION) Versus M/s SUMITOMO CORPORATION</h3> The Supreme Court of India dismissed the special leave petitions, with the question of law left open. Delay was condoned, and the court did not address ... Fees for technical services received - computation of period of stay - whether taxable by reason of article 12(2) of the DTAA with Japan? - HELD THAT:- The essential question is whether Article 12(2) or 12(5) of the Agreement which is applicable in these cases. In the facts of these cases, we are not inclined to go into this aspect. The special leave petitions are, accordingly, dismissed The Supreme Court of India dismissed the special leave petitions, with the question of law kept open. Delay was condoned, and the court did not delve into the applicability of Article 12(2) or 12(5) of the Agreement in the cases. Pending application(s) were disposed of.
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