2024 (9) TMI 31 - SCH - Income Tax

Revision u/s 263 - Tribunal setting aside an order passed by the Commissioner u/s 263 which is a second proceedings initiated under the said provision - addition u/s 68 - delay filling SLP - As decided by HC 2022 (11) TMI 1432 - CALCUTTA HIGH COURT after the first order was passed u/s 263 AO has conducted a de novo reassessment proceedings, issued summons to the directors and the shareholders as well as the assessee and examined the books of accounts, bank statement and the other documents produced to discharge the onus on them about the identity, creditworthiness and genuineness of the transaction and the AO has recorded their statement during the reassessment proceedings where he has questioned an elucidated answer about all these factors. Tribunal has elaborately discussed the factual position and noted as to how the enquiry was conducted by the assessing officer after the first order was passed u/s 263. HELD THAT - There are no justifiable grounds for condoning the delay of 530 days. The special leave petition is dismissed on the ground of delay.