2023 (8) TMI 1348

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..... hat 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 .....

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