2025 (4) TMI 1138 - SCH - Income Tax

Validity of Revision u/s 263 as set aside by ITAT - estimation of bogus expenditure - As decided by HC 2023 (7) TMI 1570 - CALCUTTA HIGH COURT invoking his power u/s 263 has proceeded based on conjecture and there is no finding recorded that the books of accounts of the assessee were rejected. The specific issue raised by the assessee that the documents and details were furnished before the assessing officer was not found to be incorrect. HELD THAT - No satisfactory explanation has been offered to condone the delay in filing the Special Leave Petition. Even otherwise on merits also no case for interference is made out in exercise of our jurisdiction under Article 136 of the Constitution of India. The Special Leave Petition is accordingly dismissed on the ground of delay as well as on merits.

Summary

The Supreme Court, through Hon'ble Justices Abhay S. Oka and Ujjal Bhuyan, dismissed the Special Leave Petition both on the ground of delay and on merits. The Court noted that "No satisfactory explanation has been offered to condone the delay in filing the Special Leave Petition." Further, exercising jurisdiction under Article 136 of the Constitution of India, the Court held that "no case for interference is made out." Consequently, the petition was dismissed and any pending applications were disposed of.