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of <h1>Supreme Court Dismisses Petition Due to 531-Day Filing Delay and Prior Decision, Ends Legal Recourse for Petitioners.</h1> <h3>COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION) -2 Versus NET APP BV</h3> The SC dismissed the SLP due to a filing delay of 531 days and because the issue was already adjudicated in a prior decision. Consequently, the review ... TDS u/s 195 - Royalty - amounts paid by the concerned persons resident in India to non-resident, foreign software suppliers - Whether constitutes as taxable income deemed to accrue in India u/s 9(1)(vi)? - interest u/s 234B - Delay filling SLP - HELD THAT:- Besides the delay of 531 days in filing the Special Leave Petition, the issue sought to be raised by the Revenue is covered by the decision of this Court in Engineering Analysis Centre of Excellence Private Limited [2021 (3) TMI 138 - SUPREME COURT] Counsel appearing on behalf of the petitioner states that the review petition has also been dismissed. The Supreme Court dismissed the Special Leave Petition due to a delay of 531 days in filing and because the issue raised was covered by a previous court decision. The review petition was also dismissed.
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