2023 (3) TMI 483

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....l. For the Respondent Through: None. RAJIV SHAKDHER, J.: (ORAL) CM No.5866/2023[Application filed on behalf of the appellant seeking condonation of delay of 180 days in re-filing the appeal] 2. This is an application filed on behalf of the appellant/revenue seeking condonation of delay in re-filing the appeal. 2.1 There is a delay of 180 days. 3. The reason given is that certain ....

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....es, 1962 [in short, "1962 Rules"]. 7. A finding of fact has been returned by the Commissioner of Income Tax Appeals [in short, "CIT(A)"] to the effect that the appellant made investment in subsidiary/associated companies for strategic purposes. 7.1 The CIT(A) has also found that the respondent/assessee has not earned any dividend income which was exempted under the Act. 7.2 The Tribunal h....

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....arma, who appears on behalf of the appellant/revenue, has fairly placed before us a judgment dated 20.07.2022, rendered by a coordinate bench of this Court in ITA No.204/2022, titled Principal Commissioner of Income Tax (Central)-2 v. M/s Era Infrastructure (India) Ltd., which has ruled on the amendment which was brought about in Section 14A of the Act via Finance Act 2022. 8.1. The coord....