Statutory time limit for producing agreements under section 80-O could not be relaxed without express condonation power.

Section 80-O required the relevant agreements to be produced by the prescribed date for the first assessment year in which approval was sought, and the statute did not provide for condonation of delay in filing them. In the absence of any application for condonation before the Central Board of Direct Taxes, the High Court could not direct that the delay be condoned or require the matter to be examined on merits. The Court therefore held that the delay in producing the agreements was not capable of condonation under the statute, and the direction to condone it was unsustainable.

---

---

Issues: Whether delay in producing the agreements required for approval under section 80-O of the Income-tax Act, 1961 could be condoned by the High Court in the absence of any provision in the statute permitting such condonation.

Analysis: Section 80-O required the relevant agreements to be produced before the prescribed date for the assessment year in relation to which approval was first sought. The statute contained no provision enabling condonation of delay in the production of such agreements. No application for condonation had been made before the Central Board of Direct Taxes. In these circumstances, the High Court was not justified in directing that the delay be condoned and that the matter be examined on merits.

Conclusion: The delay could not be condoned by the High Court, and the order directing such condonation was unsustainable.

---