598-day delay in filing tax petition over off-the-shelf software "royalty" under Article 12(3) not condoned; case dismissed.

The dominant issue was whether a 598-day delay in filing the petition should be condoned. Applying the standard for condonation, the SC held that no sufficient cause was shown to justify such delay. The application for condonation was therefore dismissed, and as a consequence the SLP was dismissed without examination of the substantive tax issue (whether consideration for off-the-shelf software constituted "royalty" under Article 12(3) of the Indo-Singapore DTAA), with the question of law left open.

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The Court, after hearing counsel for the petitioner, held that no sufficient case was made out "for condoning delay of 598 days in filing the present petition." Accordingly, the "application for condonation of delay in filing the present petition is dismissed." As a consequence, "the Special Leave Petition is also dismissed, leaving the question of law open." Any pending application(s) were ordered to "stand disposed of."

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