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The present appeal is dismissed both on the ground of limitation as well as on merits as no question of law arises for our consideration under s. 260A of the Act.

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Section 260A(2A) of the Income Tax Act, 1961 — Appeal — Appeal to High Court — Application is dismissed as it does not disclose any cogent ground or reason for seeking condonation as grounds and reasons stated in the application seeking condonation of delay are completely bereft of merits. Assessee cannot be permitted to bring new and additional evidence in the proceeding under section 260A and accordingly, the sale deed shown to the Court relied upon to prove the creditworthiness of Ms JK is disregarded—Sidharth Export vs. Assistant Commissioner of income tax [2019] 311 CTR (Delhi) 663

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