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of <h1>Inordinate 538-day delay in filing SLP prevents judicial review; petition dismissed for failure to show condonation</h1> Dominant issue: whether the inordinate delay of 538 days in filing the SLP should be condoned. Reasoning: applying the Court's strict requirement for a ... Royalty v/s business income - distribution revenue earned by the appellant assessee - taxed as royalty, as per section 9(1)(vi) and Article 12 of the DTAA between India and the USA OR a business income - Delay of 538 days in filing this Special Leave Petition As decided by HC [2024 (3) TMI 1349 - DELHI HIGH COURT] fact of the Mutual Agreement Procedure having been adhered to by respective parties and consequent to the adjudication completed therein, the assessee having agreed to pay 10% of advertising and subscription revenue is not disputed. HELD THAT:- As we do not find any plausible and bona fide explanation to condone this inordinate delay. Special Leave Petition is, accordingly, dismissed on the ground of delay. Outcome: Special Leave Petition dismissed on the ground of delay.
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