https://www.taxtmi.com/caselaws?id=785006 Dispute concerned whether distribution revenue earned by the assessee was taxable as royalty under section 9(1)(vi) and Article 12 of the India-US DTAA, or as business income. The text notes that the parties had followed the Mutual Agreement Procedure and that the assessee had agreed to pay 10% of advertising and subscription revenue. The Supreme Court refused to condone a delay of 538 days in filing the Special Leave Petition, finding no plausible or bona fide explanation, and dismissed the petition on that ground. 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 Dispute concerned whether distribution revenue earned by the assessee was taxable as royalty under section 9(1)(vi) and Article 12 of the India-US DTAA, or as business income. The text notes that the parties had followed the Mutual Agreement Procedure and that the assessee had agreed to pay 10% of advertising and subscription revenue. The Supreme Court refused to condone a delay of 538 days in filing the Special Leave Petition, finding no plausible or bona fide explanation, and dismissed the petition on that ground. Case-Laws Income Tax Tue, 13 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=785006