2024 (7) TMI 663 - SCH - Income Tax

Condonation of delay in filling appeal before SC - delay of 215 days - TP adjustment - rejection of AMP adjustment using BLT method - AMP does not constitute an international transaction - ITAT justification in holding that the AMP cannot be inferred to be international transaction in the absence of any agreement, arrangement or understanding between the taxpayer and its AE - depreciation amounting to Rs. 37,54,845/- on de-capitalized assets - HC decided issues 2023 (8) TMI 1117 - DELHI HIGH COURT in favour of assesee - HELD THAT - The explanation for condoning the delay of 215 days in filing the Special Leave Petition is inadequate and does not constitute sufficient cause to condone the delay. The Special Leave Petition is accordingly dismissed on the ground of limitation. Since the Special Leave Petition is dismissed on the ground of limitation, we clarify that we have not expressed any opinion on the merits of the legal issue involved which may be decided in any other appropriate case.

Summary

The Supreme Court dismissed the Special Leave Petition due to a delay of 215 days in filing, citing insufficient cause for condonation. The dismissal was based on the ground of limitation, with no opinion expressed on the merits of the legal issue. Any pending applications were disposed of accordingly.