2000 (7) TMI 69

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.... that is under challenge. The order noted that the application of the respondent before us under section 80-O of the Income-tax Act, 1961, in regard to the two agreements that had been entered into by it on January, 3, 1979, and February 20, 1979, with a party in the United States of America were not approved for the assessment year 1981-82 on the ground that they had been produced only on Septemb....

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....ndone delay under the provisions of section 119. The provisions of section 80-O mandate the production of the agreements in respect of which relief is sought, "before the 1st day of October of the assessment year in relation to which the approval is first sought", and there is no provision for the condonation of such delay. There was also no application before the Central Board for condonation ....