(Sanjiv Khanna and M.M. Sundresh, JJ.)
Petition(s) for Special Leave to Appeal (C) No(s). 92/2023 @ Diary No. 38156/2022, decided on January 3, 2023
Joint Commissioner of Income Tax and Another _________ Petitioner(s);
v.
Cognizant Technology Solutions India Pvt. Ltd. ________ Respondent(s).
(For Admission and I.R. and IA No. 194262/2022-Condonation of Delay in Filing)
Petition(s) for Special Leave to Appeal (C) No(s). 92/2023 @ Diary No. 38156/2022; WA No. 2521/2021; and IA No. 194262/2022
The Order of the court was delivered by
Order
1. Delay condoned.
2. In view of the findings recorded by the High Court in re questions raised and answers given, before, the assessment order under Section 143(3) of the Income Tax Act, 1961 was passed, we are not inclined to issue notice in the present special leave petition. The assessee has no role to play and is not the author of the assessment order and hence the manner and contents of the assessment order as framed is not determinative whether or not it is a case of change of opinion.
3. Recording the aforesaid, the special leave petition is dismissed.
4. Pending application(s), if any, shall stand disposed of.
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