https://www.taxtmi.com/caselaws?id=783513 SC dismissed the assessee's Special Leave Petition challenging the HC's treatment of distribution revenue under section 9(1)(vi) and Article 12 of the India-USA DTAA. The HC had relied on the Mutual Agreement Procedure outcome, under which the assessee accepted 10% of advertising and subscription revenue as taxable in India, and this was not disputed. The SC held that the assessee failed to furnish any plausible or bona fide explanation for the inordinate delay of 464 days in filing the petition and therefore dismissed it solely on the ground of delay. en-us Mon, 15 Dec 2025 00:00:00 +0530 Wed, 17 Dec 2025 08:28:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783513 SC dismissed the assessee's Special Leave Petition challenging the HC's treatment of distribution revenue under section 9(1)(vi) and Article 12 of the India-USA DTAA. The HC had relied on the Mutual Agreement Procedure outcome, under which the assessee accepted 10% of advertising and subscription revenue as taxable in India, and this was not disputed. The SC held that the assessee failed to furnish any plausible or bona fide explanation for the inordinate delay of 464 days in filing the petition and therefore dismissed it solely on the ground of delay. Case-Laws Income Tax Mon, 15 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783513