(Sanjiv Khanna and S.V.N. Bhatti, JJ.)
Special Leave Petition (Civil) Diary No. 36877/2023, decided on October 9, 2023
Assistant Commissioner of Income Tax and Others _____ Petitioner(s);
v.
Asian Paints Limited ______________________________ Respondent.
(For Admission and I.R. and IA No. 204428/2023-Condonation of Delay in Filing and IA No. 204432/2023-Exemption From Filing C/C of the Impugned Judgment)
SLP(C) Diary No. 36857/2023
(For Admission and I.R. and IA No. 190484/2023-Condonation of Delay in Filing and IA No. 190485/2023-Exemption From Filing C/C of the Impugned Judgment)
Special Leave Petition (Civil) Diary No. 36877/2023; WP No. 1425/2022; IA No. 204428/2023; IA No. 204432/2023; SLP(C) Diary No. 36857/2023; IA No. 190484/2023; and IA No. 190485/2023
The Order of the court was delivered by
Order
1. Delay condoned.
2. It is stated that in the present cases, notice under Section 148 of the Income Tax Act, 1961 (Act) was issued after the expiry of four years from the end of the relevant assessment year.
3. Further, the income tax returns were taken up for regular assessment and thereafter, order under Section 143(3) of the Act was passed.
4. There is a categorical finding by the High Court that full material facts with regard to the expenditure in question were placed by the assessee – Asian Paints Ltd. before the Assessing Officer during the course of the regular assessment proceedings.
5. In view of the aforesaid, we do not find any merit in the present special leave petitions and the same are dismissed.
6. Pending application(s), if any, shall stand disposed of.
———
