Fixed place permanent establishment dispute remained undecided as the Special Leave Petition failed for unexplained filing delay.

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....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.....