TDS u/s 194C/194I - External Development Charges (EDC) were received by HUDA from some private persons/builders in which TDS has not been deducted - HELD THAT:- Following the order passed by this Court in DLF Homes Panchkula Pvt. Ltd.[2024 (2) TMI 1203 - SC ORDER] we dismiss this special leave petition also.

Rectification application - non-adjudication of appellate grounds - Recall of the appellate order on the ground that grounds Nos. 2 to 5 had not been adjudicated - As decided by HC Tribunal had considered the contention regarding alleged non-adjudication and found that the said grounds had already been considered and rejected. No ground for interference was therefore made out. Final Conclusion: The appeal was dismissed, as the grounds alleged to have remained undecided had in fact been considered by the Tribunal.

Validity of penalty 271(1)(c) - notice for concealment or furnishing inaccurate particulars - Ambiguous show-cause notice as foundation for penalty - Defective notice HELD THAT:- We find no grounds to interfere with the impugned judgment and order of the High Court [2025 (11) TMI 2043 - BOMBAY HIGH COURT]. Hence, the present Special Leave Petition stands dismissed. Question of law, if any, is kept open.

Treatment of bottle deposits as trading receipt - classification of beer bottles as plant - allowability of capital loss on renunciation of rights shares - notional loss versus realised loss - remand for fresh adjudication of taxability of non-competition fee - scope of appellate tribunal when first appellate authority remands for fresh consideration HELD THAT:- The appeals were dismissed, no ground being found to interfere with the common impugned judgment and order [2010 (2) TMI 622 - KARNATAKA HIGH COURT]

TDS u/s 195 - Payments for purchase of software from non-residents - Royalty characterisation of software licence payments - as decided by HC [2025 (3) TMI 1749 - KARNATAKA HIGH COURT] software purchase payments to non-residents were not royalty and did not require withholding u/s 195 was sustained. Delay of 307 days in filing the Special Leave Petition HELD THAT:- The reasons assigned for seeking condonation of delay are neither satisfactory nor sufficient in law so as to condone the same. Hence, the application seeking condonation of delay is dismissed. Consequently, the Special Leave Petition is also dismissed on the ground of delay.

Authentication of electronically generated reassessment notice - Requirement of signature on notice under the Income-tax Act HELD THAT:- The Special Leave Petition was dismissed, with no interference in the impugned High Court order [2026 (4) TMI 1900 - DELHI HIGH COURT] wherein held though a digital signature may be appropriate, the provision does not mandate it; the absence of such signature did not render the notice irregular or invalidate the reassessment proceedings.

Overriding effect of the MPID Act - Jurisdiction of the Special Court over seized assets - Protection of depositors through release of funds to escrow - Conflict between special statutes -Protection of depositors through release of funds to escrow - Lawful settlement HELD THAT:- We do not find any reason to interfere with the impugned order[2026 (3) TMI 1573 - BOMBAY HIGH COURT] The Special Leave Petition is hence dismissed.

Prior approval under Section 153D - Approval not to be mechanical - application of mind - CBDT Circular and Manual of Office Procedure binding on department - Requirement of mentioning approval in assessment order - Rules of natural justice in administrative orders entailing civil consequences HELD THAT:- We find that in case of the very same respondent in [2023 (11) TMI 1254 - SC ORDER] this Court dismissed the Special Leave Petition. Having regard to the facts and circumstances of the case, following the said order, we dismiss this Special Leave Petition also on merits as well as on delay. HC order confirmed.[2023 (3) TMI 785 - ORISSA HIGH COURT]

Prior-period expenditure - crystallisation of liability - Allowability of prior-period expenses claimed on crystallisation of the liability during the relevant year - HELD THAT:- Additional Solicitor General appearing for the petitioner(s) has brought to the notice of this Court the synopsis filed in the instant case which would indicate that the High Court has relied upon the judgment of Indian Petrochemicals Corporation Ltd. [2016 (9) TMI 110 - GUJARAT HIGH COURT]The said order was in favour of the assessee(s) against which the Revenue had filed an appeal in SLP and this court by order dated [2017 (7) TMI 1490 - SC ORDER] which had issued the notice and ultimately dismissed the same vide order [2026 (1) TMI 1264 - SC ORDER] Connected matters have also been dismissed by order of even date. Assessee(s) has also brought to the notice of this court the judgment of this court rendered in Kerala State Electricity Board [2022 (10) TMI 363 - SC ORDER] and the Special Leave Petition filed by the assessee(s) came to be dismissed as indicated in paragraph No. 7 of said judgment. In that view of the matter, the present Special Leave Petitions also stand dismissed as the issue being no more res integra. Consequential order of penalty - penalty under Section 271(1)(c) in relation to deleted additions - HELD THAT:- In view of the order passed today [ supra] the present Special Leave Petitions would not survive as it is the consequential order of penalty levied which has been challenged. Accordingly, these Special Leave Petitions also stand dismissed.

Validity of reopening of assessement - mandation to get approval/sanction of the competent authority as contemplated u/s 151 - notice issued within a period of four years - Extended Period of Limitation as per IT Act read with TOLA - HELD THAT:- We are not inclined to entertain the Special Leave Petition. The same is accordingly dismissed. HC [2025 (11) TMI 46 - BOMBAY HIGH COURT] reasoning confirmed.

Profit on sale of investments - Assessee carrying on a general insurance business - disallowance under Section 40(a)(i) for non-deduction of tax - depreciation rate on UPS as integral part of computer - applicability of minimum alternate tax / Section 115JB to insurance companies - rule of consistency in departmental assessments HELD THAT:- Delay was condoned and the Special Leave Petition was dismissed without interference with the impugned order [2025 (6) TMI 1488 - MADRAS HIGH COURT].

Bogus share trading loss - Retraction of statement on oath - Perverse appellate order - As decided by HC [2025 (7) TMI 2053 - CALCUTTA HIGH COURT] Tribunal's deletion of the disallowance was held perverse as assessee neither substantiated the loss through documents nor appeared before the AO. The Tribunal failed to appreciate this material factual position and its reliance on the retraction and its finding regarding cross-examination were held erroneous and indicative of non-application of mind. HELD THAT:- Delay was condoned and the Special Leave Petition was dismissed, no ground being found to interfere with the impugned order.

Issuance of a notice u/s 153C - Mandation of recording of the satisfaction note - delay of 22 months in recording the satisfaction - As per HC impugned notices under Section 153C (AY 2017-18) quashed and set aside for failure to record the requisite satisfaction note within the immediate period mandated by the Calcutta Knitwears ratio [2014 (4) TMI 33 - SUPREME COURT] and Circular No. 24/2015 HELD THAT:- No good ground to interfere with the impugned order passed by the High Court. Special Leave Petition is, accordingly, dismissed.

Maintainability of a Revenue appeal having tax effect below the monetary limit - Revenue invoked exceptions introduced by subsequent CBDT Circulars - Prospective application of exceptions to monetary limit circulars - Applicability of revised monetary limits to pending income-tax appeals HED THAT:- Having heard the Revenue and having gone through the materials on record, we find no good reason to interfere with the impugned orders passed by the High Court. [2025 (12) TMI 1872 - BOMBAY HIGH COURT] The Special Leave Petitions are, accordingly, dismissed.

Revision u/s 264 - characterization of the income declared under the IDS, 2016 - Credit of the tax paid under the IDS, 2016 - HELD THAT:- We find no grounds to interfere with the impugned judgment and order of the High Court [2025 (12) TMI 74 - BOMBAY HIGH COURT]. Hence, the Special Leave Petition is dismissed.

Revision of assessment order prejudicial to Revenue - Twin conditions for revisionary jurisdiction - Revisionary jurisdiction in limited scrutiny assessment - Scope of limited scrutiny HELD THAT:- After going through the impugned order passed by the High Court [2025 (11) TMI 2036 - ALLAHABAD HIGH COURT] as well as the order passed by the Income Tax Appellate Tribunal [2025 (4) TMI 1844 - ITAT AGRA] we are not inclined to entertain the Special Leave Petition.

Revision u/s 263 - Right to be heard / Audi alteram partem in revision proceedings - Treaty shopping and conduit arrangements - Permanent establishment and taxation as fees for technical services - Applicability of DTAA benefits contingent on factual determination - delay in filling SLP High Court [2024 (11) TMI 368 - DELHI HIGH COURT] dismissed the Revenue's appeal and ITAT's decision setting aside the Commissioner's Section 263 order was upheld because the assessee was not afforded an opportunity to meet the allegation of being a conduit/treaty shopping arrangement; consequently no substantial question of law warranted interference. HELD THAT:- The Special Leave Petition was dismissed on the ground of inordinate delay in filing.

Accrual of income in India - global online learning platform providing online courses and degrees from leading universities and companies - scope of “Make Available” - chargeable to tax as FTS and FIS a under the Indo-US DTAA HELD THAT:- We are not inclined to interfere with the impugned judgment and order passed by the High Court [2025 (11) TMI 2033 - DELHI HIGH COURT] The Special Leave Petition is dismissed

Fixed Place Permanent Establishment (PE) in India - taxability, the existence of a PE and attribution of income - whether NIPL would constitute a PE of Nokia OY? - whether the Liaison Office could be treated as a PE? - delay of 383 days in filing the Special Leave Petition. HELD THAT:- Reasons assigned for seeking condonation of delay are neither satisfactory nor sufficient in law so as to condone the delay. Hence, the application seeking condonation of delay is dismissed. Consequently, the Special Leave Petition is dismissed. We note that the petitioner was aware of the fact that in respect of the matter as against the very same respondents involving the very same issues, this Court had dismissed the Special Leave Petition on the ground of gross delay of 286 days in filing the Special Leave Petition [2026 (4) TMI 1197 - SC ORDER]. We fail to understand as to how this Special Leave Petition could have been filed subsequently with 383 days delay. Filing of this Special Leave Petition with a greater delay of 383 days on the very same issue only for the sake of seeking a dismissal on the ground of delay could have been avoided by the Department.

Reopening of assessment - Reasons to believe - Survey u/s 133A - Permanent Establishment - Dependent Agent Permanent Establishment - Fixed Place Permanent Establishment - tangible material to form belief - chargeability of business income attributable to PE - reliance on precedent HELD THAT:- No good ground to interfere with the impugned order(s) passed by the High Court [2025 (5) TMI 2058 - DELHI HIGH COURT] Special Leave Petitions are, accordingly, dismissed