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There is a delay of 254 days in filing the special leave petition for which no reasonable explanation has been given. Even otherwise there is no merit in this special leave petition. The same is, accordingly, dismissed both on the ground of delay and merit.

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Sec. 271D of the Income-tax Act, 1961 – Penalty – The assessee's returns for A.Y. 1992-93 got processed by scrutiny order under 143(3) of the Act, 1961. In the course of the assessment, the AO was of the opinion that the sum of Rs.61,00,520/- had been received by the assessee contrary to Section 269-SS. A proposal was issued to the DCIT for proceeding after imposition of penalty under 271D of the 1961 Act, who accepted the sum and confirmed the penalty which was levied. The CIT (A) was of the opinion that the amount accepted was Rs.1,06,44,500/- and that there was a error. A Show Cause Notice was issued for enhancement of the amount and after considering the submissions of the assessee, the penalty proposed under Section 271D was levied. The ITAT rejected the assessee's appeal. High Court while set asiding the impugned orders restored the matter back to AO to consider all the materials afresh and pass appropriate orders, having regard to the current position, in accordance with law on the merits as to the valuation, if any, under Section 269-SS of the Act. SLP of the revenue dismissed on its merits and delay – ASIAN CONSOLIDATED INDUSTRIEAL LTD. [2020] 270 TAXMAN 184 (SC)

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