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of <h1>Special leave petition dismissed; draft and final assessment orders barred by limitation under s.153(2A), no substantial question of law</h1> <h3>The Commissioner of Income Tax International Taxation 3, Delhi Versus Qualcomm Incorporated.</h3> SC dismissed the special leave petition, upholding the Tribunal's view-based on HC precedent-that both the draft and final assessment orders are barred by ... Validity of draft assessment order and final assessment order as barred by limitation u/s 153(2A) - Scope of the word “received” - Tribunal held the draft assessment order and final assessment order passed by the AO are barred by limitation u/s 153(2A) - As decided by HC [2024 (2) TMI 1046 - DELHI HIGH COURT] ITAT has while passing the orders impugned before us proceeded on the basis of the principles enunciated in the aforenoted two decisions. We thus find no justification to interfere with the view as expressed. The appeal raises no substantial question of law HELD THAT:- We are not inclined to entertain this special leave petition. The special leave petition is, accordingly, dismissed. 'Delay condoned.' The Court recorded that, after hearing counsel for the petitioner, it was 'not inclined to entertain this special leave petition' and the 'special leave petition is, accordingly, dismissed.' The ruling therefore denies discretionary SLP relief sought by the petitioner, with no further substantive adjudication of the underlying merits. The Court also ordered that 'Pending application(s), if any, shall stand disposed of.' The decision reflects a procedural disposition: condonation of delay was granted, but the petition was rejected at the threshold for admission under Article 136, resulting in dismissal and termination of any attendant interim or ancillary applications.
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