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of <h1>SLP dismissed, upholding earlier findings that Commissioner's invocation under Section 263 was unjustified after AO enquiries and delay condoned</h1> <h3>PRINCIPAL COMMISSIONER OF INCOME TAX CENTRAL-1 Versus M/s RANI SATI AGRO TECH PVT. LTD.</h3> SC dismissed the Special Leave Petition, upholding HC and ITAT findings that the Commissioner of Income Tax's invocation of power under s. 263 was ... Revision u/s 263 - whether in the second round of litigation Commissioner of Income Tax was justified in invoking his power u/s 263? - as decided by HC [2024 (8) TMI 119 - CALCUTTA HIGH COURT] Tribunal was fully justified in concluding in favour of the assessee after noting that the assessing officer had conducted extensive enquiry on issues and directions mentioned in the order passed u/s 263 of the Act. Thus we find no grounds have been made out to interfere with the order passed by the learned Tribunal. HELD THAT:- Delay condoned. In the facts to the case, no interference is called for with the view taken by the Income Tax Appellate Tribunal as well as the High Court. The Special Leave Petition is, accordingly, dismissed. The Supreme Court, through Justices Abhay S. Oka and Ujjal Bhuyan, heard the petitioner's counsel and condoned the delay. However, the Court found that 'no interference is called for with the view taken by the Income Tax Appellate Tribunal as well as the High Court.' Consequently, the Special Leave Petition was dismissed, and any pending applications were disposed of accordingly.
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