https://www.taxtmi.com/caselaws?id=785006 Characterisation of distribution revenue as royalty or business income under the IndiaUS tax treaty and domestic tax law is examined, with the Mutual Agreement Procedure having resulted in the assessee agreeing to remit 10% of advertising and subscription receipts; that MAP outcome was not contested. The Special Leave Petition was filed 538 days late and the Court found no plausible explanation for the delay, resulting in dismissal of the petition on the ground of inordinate delay, thereby terminating judicial review of the substantive treaty characterisation. en-us Tue, 13 Jan 2026 00:00:00 +0530 Thu, 15 Jan 2026 08:41:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=785006 Characterisation of distribution revenue as royalty or business income under the IndiaUS tax treaty and domestic tax law is examined, with the Mutual Agreement Procedure having resulted in the assessee agreeing to remit 10% of advertising and subscription receipts; that MAP outcome was not contested. The Special Leave Petition was filed 538 days late and the Court found no plausible explanation for the delay, resulting in dismissal of the petition on the ground of inordinate delay, thereby terminating judicial review of the substantive treaty characterisation. Case-Laws Income Tax Tue, 13 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=785006