https://www.taxtmi.com/caselaws?id=784722 The dominant issue was whether a 598-day delay in filing the petition should be condoned. Applying the standard for condonation, the SC held that no sufficient cause was shown to justify such delay. The application for condonation was therefore dismissed, and as a consequence the SLP was dismissed without examination of the substantive tax issue (whether consideration for off-the-shelf software constituted "royalty" under Article 12(3) of the Indo-Singapore DTAA), with the question of law left open. en-us Tue, 06 Jan 2026 00:00:00 +0530 Mon, 13 Jul 2026 14:56:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=784722 The dominant issue was whether a 598-day delay in filing the petition should be condoned. Applying the standard for condonation, the SC held that no sufficient cause was shown to justify such delay. The application for condonation was therefore dismissed, and as a consequence the SLP was dismissed without examination of the substantive tax issue (whether consideration for off-the-shelf software constituted "royalty" under Article 12(3) of the Indo-Singapore DTAA), with the question of law left open. Case-Laws Income Tax Tue, 06 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784722