2025 (4) TMI 618 - SCH - Income Tax

Tax Collection at Source (TCS) - Addition u/s 206C(6)/206C(7) - Tribunal held that Swan timber is different from timber when there is no distinction drawn under Section 206C except in the case of timber obtained under forest lease - HC concluded 2022 (7) TMI 1271 - CALCUTTA HIGH COURT if the timber is being sized sawn into logs of different dimensions and shapes in activities carried on saw mills authorised by the Government it would amount to a different produce. Even in respect of timbers which are procured as described in table if it is used in the process of manufacturing the provision of Section 206C(1) of the Act would not be applicable due to the fact that the product ceased to be a forest produce. HELD THAT - There is a delay of 880 days in filing the Special Leave Petition which has not been satisfactorily explained. Even otherwise we have gone through the Special Leave Petition and do not find any merit in the same. Special Leave Petition is therefore dismissed on the ground of delay as well as on merits.

Summary

The Supreme Court, with Hon'ble Justices J. B. Pardiwala and R. Mahadevan presiding, dismissed the Special Leave Petition due to an "880 days" delay in filing, which was not "satisfactorily explained." The Court also found no merit in the petition itself. Consequently, the petition was dismissed "on the ground of delay as well as on merits." Any pending applications were also disposed of.