HC Closes Appeal on 2014 Tax Dispute After Delay Granted and Issue Covered by Supreme Court Judgment.

The HC granted the condonation of a 120-day delay in re-filing the appeal, as the respondent did not oppose it. The appeal related to the Assessment Year 2014-2015, where the Income Tax Appellate Tribunal had ruled in favor of the respondent. Both parties agreed that the issue was covered by a Supreme Court judgment, leading the HC to conclude that no substantial question of law arose. Consequently, the appeal was closed.

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Issues Involved:
1. Condonation of delay in re-filing the appeal.
2. Appeal concerning Assessment Year 2014-2015 with reference to a Supreme Court judgment.

Analysis:

Issue 1: Condonation of Delay
The appellant/revenue filed an application seeking condonation of a 120-day delay in re-filing the appeal. The respondent/assessee did not oppose the appellant's request for condonation. Consequently, the court granted the condonation of delay, and the application was disposed of accordingly.

Issue 2: Appeal Concerning Assessment Year 2014-2015
The appeal in question pertained to the Assessment Year 2014-2015. The Income Tax Appellate Tribunal had ruled in favor of the respondent/assessee in an order dated 08.04.2022. Both parties acknowledged that the issue raised in the appeal was covered by a judgment of the Supreme Court in Engineering Analysis Centre of Excellence Pvt. Ltd. v. CIT [2021] 432 ITR 471 [SC]. As a result, the court found that no substantial question of law arose for consideration in the present appeal and subsequently closed the appeal based on this assessment.

In summary, the High Court of Delhi addressed the application for condonation of delay in re-filing the appeal and then proceeded to close the appeal concerning the Assessment Year 2014-2015 after determining that the issue raised was covered by a relevant Supreme Court judgment, thereby finding no substantial question of law to consider further.

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