2023 (8) TMI 1348 - SCH - Income Tax

Revision u/s 263 by CIT - deemed dividend addition u/s 2(22) - As decided by HC 2022 (1) TMI 796 - CALCUTTA HIGH COURT Tribunal correctly noted that AO has taken a conscious decision bearing in mind the legal position that section 2(22)(e) was not applicable to the loan amount received by the assessee and allowed the appeal filed by the assessee and granted relief - HELD THAT - There is a huge delay of 470 days in filing the special leave petition and the same has not been explained to the satisfaction of this Court. Hence, the special leave petition is dismissed on the ground of delay as well as on merits.

Summary

The Supreme Court dismissed the special leave petition due to a delay of 470 days in filing, without satisfactory explanation. The dismissal was based on both delay and merits, with pending applications also disposed of.