https://www.taxtmi.com/caselaws?id=783897 The dominant issue was whether the SLP could be entertained despite delay. Applying limitation principles, the SC held that the unexplained delay of 571 days was fatal to maintainability, warranting dismissal without examining merits. Consequently, the SLP was dismissed as time-barred, while the question of law on characterisation and accrual in India of sublicensing receipts (including whether fees for live transmission constitute "royalty" under s. 9(1)(vi)) was expressly kept open. en-us Fri, 19 Dec 2025 00:00:00 +0530 Wed, 24 Dec 2025 07:51:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783897 The dominant issue was whether the SLP could be entertained despite delay. Applying limitation principles, the SC held that the unexplained delay of 571 days was fatal to maintainability, warranting dismissal without examining merits. Consequently, the SLP was dismissed as time-barred, while the question of law on characterisation and accrual in India of sublicensing receipts (including whether fees for live transmission constitute "royalty" under s. 9(1)(vi)) was expressly kept open. Case-Laws Income Tax Fri, 19 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783897