https://www.taxtmi.com/caselaws?id=759096 Condonation of a 384-day delay in filing the special leave petition was refused because the explanation was neither satisfactory nor sufficient in law, so the delay application was dismissed. The merits were also treated as covered by the Supreme Court's ruling in Engineering Analysis Centre of Excellence Pvt. Ltd., which held the field on royalty, TDS under section 195, and income deemed to accrue in India under section 9(1)(vi) in the DTAA context; the petition was therefore found covered by binding precedent, including the position sustained in the related review proceedings. en-us Fri, 20 Sep 2024 00:00:00 +0530 Thu, 30 Apr 2026 12:28:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=759096 Condonation of a 384-day delay in filing the special leave petition was refused because the explanation was neither satisfactory nor sufficient in law, so the delay application was dismissed. The merits were also treated as covered by the Supreme Court's ruling in Engineering Analysis Centre of Excellence Pvt. Ltd., which held the field on royalty, TDS under section 195, and income deemed to accrue in India under section 9(1)(vi) in the DTAA context; the petition was therefore found covered by binding precedent, including the position sustained in the related review proceedings. Case-Laws Income Tax Fri, 20 Sep 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=759096