2023 (9) TMI 1326

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... t that no such issue was ever raised by CIT in the notice served upon the assessee and the assessee was not even confronted by the CIT before passing the Order - as decided by HC [ 2022 (4) TMI 1081 - BOMBAY HIGH COURT] there is a finding by the Tribunal, as noted earlier, that no issue was raised by the CIT in respect of particulars of payment made to persons specified under Section 40A(2)(b) of .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... elay of 411 days in filing the Special Leave Petition. Nevertheless, we have heard learned counsel for the petitioner on merits of the case. The delay has not been explained to the satisfaction of this Court. Neither, do we find any merit in the petition. Hence, the special leave petition is dismissed both on the ground of delay as well as on merits. Pending application(s) shall stand disposed .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X