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2023 (3) TMI 483 - HC - Income TaxCondonation of delay of 180 days in re-filing the appeal - HELD THAT:- The reason given is that certain information was required from the Income Tax Department to remove the defects. Although the reason is not satisfactory, given the fact that the impugned order was passed around the time when Corona Virus was raging in the city we are inclined to take a benevolent view. According the delay is condoned. Disallowance u/s 14A read with Rule 8D - appellant made investment in subsidiary/associated companies for strategic purposes - HELD THAT:- As a matter of fact, in the decision rendered in M/S MMTC LTD [2022 (12) TMI 651 - DELHI HIGH COURT] the Court even dealt with the amendment brought about u/s 14A of the Finance Act, 2022 - Given these circumstances, we are of the view that, insofar as this case is concerned, no substantial question of law arises for consideration. We are informed that appellant/revenue has filed a Special Leave Petition vis-a-vis the judgment in PCIT v. IL & FS Energy Development Company Ltd [2018 (5) TMI 2126 - SC ORDER] In case, appellant/revenue were to succeed, it would then have liberty to approach the court to re-open the appeal.
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