2025 (5) TMI 1598 - SCH - Income Tax

Sham collaboration agreement - addition made after adjustments towards technical expertise and brand value - addition made by the AO is the collaboration agreement as executed between the assessee and an entity named MGF Development Ltd. - Delay filling SLP - HC 2023 (12) TMI 1040 - DELHI HIGH COURT held as correctly concluded by the Tribunal the amount received by MGF had been offered for tax and quite clearly addition in that regard could not have been made in the hands of assessee once the remittance had been accepted in the hands of MGF. In a manner of speech in our view what is sauce for the goose is also sauce for the gander HELD THAT - Heard the learned ASG appearing for the petitioner. We find no reason to condone the delay of 396 days in preferring this Special Leave Petition. The Special Leave Petition is accordingly dismissed on the ground of delay.

Summary

The Supreme Court, through Hon'ble Justices Abhay S. Oka and Ujjal Bhuyan, dismissed the Special Leave Petition due to an inordinate delay of 396 days in filing. The Court stated, "We find no reason to condone the delay," and accordingly, the petition was dismissed solely on the ground of delay.