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TMI Blog2023 (11) TMI 211X X X X Extracts X X X X X X X X Extracts X X X X ..... DER PER K. NARASIMHA CHARY, J.M: Aggrieved by the order dated 29/03/2022 passed by the learned Principal Commissioner of Income Tax (PCIT), Hyderabad, under section 263 of the Income Tax Act, 1961 (for short "the Act") in the case of CSK Realtors Ltd. ("the assessee") for the assessment year 2017-18, assessee preferred this appeal. 2. Brief facts of the case are that assessee was deriving inco ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... here was no error, and the learned Assessing Officer took a conscious view after considering all the material required for verification of the levelling expenditure and satisfied with the disallowance of 10% thereof. 4. Learned DR, at the outset, submitted that there are no grounds to condone the delay because, the cause attributed by the assessee to the delay is not genuine and against the publi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... conduct of the assessee was deprecated. 5. We have gone through the record in the light of the submissions made on either side. It could be seen from the affidavit filed in support of the request of the assessee to condone the delay, it is stated that pursuant to the impugned order, the assessee thought that pursuant to the directions of the learned PCIT, the learned Assessing Officer would pass ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ssee wanted to have the best of both the worlds and having tested its luck before the learned Assessing Officer in the consequential proceedings and having lost the same, it came back to agitate the legality of the impugned order. Assessee is not an individual, but it is a commercial entity with a battery of legally trained people available for assistance. The pleas available to the individual can ..... X X X X Extracts X X X X X X X X Extracts X X X X
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