SLP dismissed as delayed, leaving s.153(2A) time-bar finding on transfer pricing reassessment orders intact, undisturbed for assessee SC dismissed the revenue's special leave petition challenging the HC's quashing of transfer pricing reassessment orders as time-barred under s.153(2A) of ...
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SLP dismissed as delayed, leaving s.153(2A) time-bar finding on transfer pricing reassessment orders intact, undisturbed for assessee
SC dismissed the revenue's special leave petition challenging the HC's quashing of transfer pricing reassessment orders as time-barred under s.153(2A) of the Income-tax Act. The HC had held that the Assessing Officer's consequential orders, passed beyond the statutory limitation period, were without jurisdiction and liable to be set aside. The SC, noting a reported delay of 632 days in filing the SLP, found no sufficient cause for condonation. Consequently, the SLP was dismissed on the ground of delay, leaving the HC judgment undisturbed.
The Supreme Court dealt with a special leave petition filed with a reported delay of 632 days. After hearing counsel for the petitioners, the Court examined whether there was "sufficient explanation to condone the delay." It found that the petitioners had not provided an adequate or satisfactory explanation for the inordinate delay in approaching the Court. Emphasizing that condonation of delay is not a matter of right and requires a convincing justification, the Court declined to exercise its discretion in favour of the petitioners. Consequently, the special leave petition was "dismissed on ground of delay." All pending applications, if any, were ordered to stand disposed of.
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