2024 (11) TMI 1035 - SCH - Income Tax

Assessment u/s 144C - TP adjustments were not received in time and the AO has confirmed the draft assessment order and the same is in violation of Section 144C - Delay filling SLP - As decided by HC 2023 (9) TMI 1575 - KARNATAKA HIGH COURT assessee is right in his submission that u/s 144C AO is bound by the directions issued by the DRP and required to pass the assessment order in conformity with the directions issued within one month from the end of month in which such directions are issued. ITAT has recorded that impugned order is not in conformity with the provisions of Section 144C of the IT Act and barred by time. Revenue appeal dismissed. HELD THAT - There is a gross and unexplained delay of 294 days in filing the Special Leave Petition. We see no good reason to interfere with the impugned order passed by the High Court of Karnataka at Bengaluru. Special Leave Petition is accordingly dismissed on the ground of delay as well as on merits.

Summary

The Supreme Court dismissed the Special Leave Petition due to a delay of 294 days in filing and found no reason to interfere with the High Court's order from Bengaluru. The pending application was also disposed of.