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<h1>Special Leave Petition Dismissed for Filing Delay</h1> <h3>PR. COMMISSIONER OF INCOME TAX Versus M/s SHAH VIRCHAND GOVANJI JEWELLERS PVT. LTD.</h3> SC dismissed the Special Leave Petition due to a 452-day filing delay without justifiable reason for condonation. - PR. COMMISSIONER OF INCOME TAX Versus ... Addition u/s.36(i)(ii) - Commission paid to directors - whether in the nature of Dividend - rule of consistency - payment to Directors/shareholders was hit by the provisions of section 36(1)(ii) as the said commission would have been payable to the Directors as dividend and accordingly, disallowed the same - Bogus purchases - Disallowance of insurance expense - Allowable revenue expenditure - HELD THAT:- There is a delay of 452 days in filing this Special Leave Petition and we do not find any justifiable reason to condone this huge delay. The Special Leave Petition is, accordingly, dismissed on the ground of delay. The Supreme Court of India dismissed the Special Leave Petition due to a delay of 452 days in filing, with no justifiable reason to condone the delay.