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    <title>Fixed place permanent establishment dispute remained undecided as the Special Leave Petition failed for unexplained filing delay.</title>
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    <description>A Special Leave Petition concerning whether NIPL or a liaison office constituted a fixed place permanent establishment in India, and the resulting taxability and income attribution, was not considered on merits. The Supreme Court found the reasons for the 383-day delay in filing insufficient in law and dismissed the condonation application and the petition. It noted that, in a matter involving the same respondents and issues, an earlier petition had already been dismissed for gross delay, and stated that the later filing could have been avoided.</description>
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    <pubDate>Sat, 01 Aug 2026 08:34:29 +0530</pubDate>
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      <title>Fixed place permanent establishment dispute remained undecided as the Special Leave Petition failed for unexplained filing delay.</title>
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      <description>A Special Leave Petition concerning whether NIPL or a liaison office constituted a fixed place permanent establishment in India, and the resulting taxability and income attribution, was not considered on merits. The Supreme Court found the reasons for the 383-day delay in filing insufficient in law and dismissed the condonation application and the petition. It noted that, in a matter involving the same respondents and issues, an earlier petition had already been dismissed for gross delay, and stated that the later filing could have been avoided.</description>
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