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<h1>Dismissal of Special Leave Petition due to Previous Dismissal; Delay Condoned</h1> The Supreme Court of India dismissed a Special Leave Petition due to a similar previous dismissal. Delay was condoned, and pending applications were ... TDS u/s 195 - Royalty - taxability of software receipts - Whether constitutes as taxable income deemed to accrue in India u/s 9(1)(vi)? - income deemed to accrue or arise in India - HELD THAT:- In view of the order passed in M/S MOL CORPORATION [2023 (5) TMI 1065 - SC ORDER] dismissing the similar Special Leave Petition wherein issue raised by the Revenue is covered against them vide judgment in the case of βEngineering Analysis Centre of Excellence Private Limited [2021 (3) TMI 138 - SUPREME COURT], the present Special Leave Petition also stands dismissed. Pending application(s) shall stand disposed of. The Supreme Court of India, with Justices M.R. Shah and C.T. Ravikumar, dismissed a Special Leave Petition due to a similar previous dismissal in SLP (C) No.5857/2023. Delay was condoned, and pending applications were disposed of. The Respondent did not appear.