https://www.taxtmi.com/caselaws?id=781285 SC dismissed the delayed SLP (403 days) for want of a plausible excuse, refusing to condone the inordinate delay. The underlying dispute concerned whether distribution revenue should be taxed as royalty under s.9(1)(vi)/DTAA Article 12 or as business income; ITAT had held it was business income, while HC noted the assessee's agreement to pay 10% of advertising and subscription revenue. The SC decision disposes of the petition on procedural delay without reaching the substantive tax question. en-us Mon, 13 Oct 2025 00:00:00 +0530 Thu, 13 Nov 2025 08:14:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=781285 SC dismissed the delayed SLP (403 days) for want of a plausible excuse, refusing to condone the inordinate delay. The underlying dispute concerned whether distribution revenue should be taxed as royalty under s.9(1)(vi)/DTAA Article 12 or as business income; ITAT had held it was business income, while HC noted the assessee's agreement to pay 10% of advertising and subscription revenue. The SC decision disposes of the petition on procedural delay without reaching the substantive tax question. Case-Laws Income Tax Mon, 13 Oct 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=781285