2024 (7) TMI 663

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..... an international transaction - ITAT justification in holding that the AMP cannot be inferred to be international transaction in the absence of any agreement, arrangement or understanding between the taxpayer and its AE - depreciation amounting to Rs. 37,54,845/- on de-capitalized assets - HC decided issues [ 2023 (8) TMI 1117 - DELHI HIGH COURT] in favour of assesee - HELD THAT:- The explanation .....

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..... el the Court made the following. 1 The explanation for condoning the delay of 215 days in filing the Special Leave Petition is inadequate and does not constitute sufficient cause to condone the delay. 2. The Special Leave Petition is accordingly dismissed on the ground of limitation. 3. Since the Special Leave Petition is dismissed on the ground of limitation, we clarify that we have not expressed .....

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