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of <h1>Special Leave Petition dismissed for 411-day delay; no merit found by Justices Nagarathna and Bhuyan.</h1> <h3>PR. COMMISSIONER OF INCOME TAX 16 Versus M/s UNIVERSAL MUSIC INDIA PVT. LTD.</h3> The Supreme Court dismissed the Special Leave Petition due to a 411-day delay in filing, finding no merit in the petition. The decision was made by ... Validity of Revision u/s 263 by CIT - payments made to persons specified under Section 40A(2)(b) allowed in assessment order - ITAT gave a finding of fact that no such issue was ever raised by CIT in the notice served upon the assessee and the assessee was not even confronted by the CIT before passing the Order - as decided by HC [2022 (4) TMI 1081 - BOMBAY HIGH COURT] there is a finding by the Tribunal, as noted earlier, that no issue was raised by the CIT in respect of particulars of payment made to persons specified under Section 40A(2)(b) of the Act and even the show cause notice is silent about that. HELD THAT:- There is a huge delay of 411 days in filing the Special Leave Petition. Nevertheless, we have heard learned counsel for the petitioner on merits of the case. The delay has not been explained to the satisfaction of this Court. Neither, do we find any merit in the petition. Hence, the special leave petition is dismissed both on the ground of delay as well as on merits. The Supreme Court dismissed the Special Leave Petition due to a 411-day delay in filing, and found no merit in the petition. The decision was made by HON'BLE MRS. JUSTICE B.V. NAGARATHNA and HON'BLE MR. JUSTICE UJJAL BHUYAN.
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