2024 (4) TMI 890 - SCH - Income Tax

Accrual of income in India - Royalty receipts - income earned from licensing/sale of software and subscription received against cloud services offered by assessee - scope of Indo-USA DTAA - delay of 301 days in filing SLP - HELD THAT - As following the earlier order passed in SLP (C) 2024 (3) TMI 670 - SC ORDER we condone the delay and dismiss the special leave petitions on the basis of the earlier judgment of this Court in the case of Engineering Analysis Centre of Excellence Private Limited vs. Commissioner of Income Tax and Anr. 2021 (3) TMI 138 - SUPREME COURT Pending application(s), if any, shall also stand disposed of.

Summary

The Supreme Court condoned a delay of 301 days in filing special leave petitions and dismissed them based on an earlier judgment related to Engineering Analysis Centre of Excellence Private Limited vs. Commissioner of Income Tax. The pending applications were also disposed of.