2024 (7) TMI 733

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..... s to facilitate loan transactions - As decided by HC [ 2023 (7) TMI 867 - DELHI HIGH COURT] jurisdictional prerequisite is a well-established principle, as reason to suspect is qualitatively different from reason to believe. The statutory [prerequisite] condition was not met by the AO before entering the realm of reassessment/assessment proceedings - HELD THAT:- There is a gross delay of 213 days .....

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..... by the petitioner is not satisfactory so as to accept the same and condone the delay as it is not sufficient in law to do so. Hence, the application seeking condonation of delay in filing the special leave petition is dismissed. Consequently, the special leave petition also stands dismissed on the ground of delay. Pending application(s), if any, shall also stand disposed of. - - TaxTMI - TMIT .....

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