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of <h1>Supreme Court Dismisses Appeal Due to 337-Day Delay; Emphasizes Importance of Timely Filing and Justifiable Delays.</h1> The SC dismissed the SLP owing to a 337-day delay in filing, which the petitioner failed to justify adequately. The decision underscores the importance of ... Delay filing appeal before Supreme court - Taxability of income India - Royalty receipts - income earned from licensing/sale of software - subscription receipts against cloud services offered by the respondent/assessee - Tribunal has ruled that neither income earned from licensing/sale of software products nor subscription fee earned for providing cloud services, could be construed as royalty - revenue, says that the proposed questions are covered by the judgment of Engineering Analysis Centre of Excellence (P.) Ltd. [2021 (3) TMI 138 - SUPREME COURT] and a review petition has been filed which is pending consideration. As decided by High Court [2023 (2) TMI 1303 - DELHI HIGH COURT] appeal is closed as no substantial question of law arises for our consideration HELD THAT:- There is a delay of 337 days in filing the Special Leave Petition. The delay which has not been satisfactorily explained. The Special Leave Petition is dismissed on the ground of limitation. The Supreme Court dismissed the Special Leave Petition due to a delay of 337 days in filing, which was not satisfactorily explained.
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