2025 (1) TMI 916

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..... ixed place and the activities carried out could not be said to be preparatory or auxiliary in nature? - income as liable to be attributed in India - existence of Dependent Agency Permanent Establishment (DAPE) of the assessee in India - delay filling SLP - As decided by HC [ 2023 (1) TMI 1244 - DELHI HIGH COURT] Liaison office of the assessee did not constitute a Permanent Establishment - HELD THA .....

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..... the following. We have heard learned counsel for the petitioner. There is gross delay of 569 days in filing this Special Leave Petition. Nevertheless, we have heard learned counsel on the merits of the matter. We are not inclined to interfere in the matter. Hence, the Special Leave Petition also stands dismissed on the ground of delay as well as on merits. In doing so, we are following our earlier .....

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