2024 (11) TMI 1573 - SCH - Income Tax

Revision under Section 263 concerning dividend exemption and unsecured loans petition dismissed after delay condonation refused

Validity of revision under the tax revision power concerns alleged excess exemption claimed for dividend income and treatment of unsecured loans, with ... Validity of Revision u/s 263 - excess claim of exemption of dividend income and that of unsecured loans - delay of 281 days in filing the present petition. HC held [2024 (12) TMI 865 - ALLAHABAD HIGH COURT] once the Tribunal on thorough scrutiny of the record has come to the conclusion that the reasons recorded by the PCIT based on Explanation 2 to Section 263 pertaining to failure of the AO in making inquiries or verification was without any basis and contrary to the record and has allowed the appeal on finding that the order passed by the PCIT was without jurisdiction, in relation to which appellants failed to point out any perversity, we do not find that the facts of the present case give rise to any substantial question of law as suggested by the appellants. HELD THAT:- After hearing the petitioner, we do not find any case is made out for condoning delay of 281 days in filing the present petition. Even on merits we do not find any case is made out for interference. The application for condonation of delay as well as Special Leave Petitions are dismissed. Outcome: Special Leave Petition dismissed on the ground of delay.