Joint Commissioner Of Income Tax v. Cognizant Technology Solutions India Pvt. Ltd.
2023-01-03
M.M.SUNDRESH, SANJIV KHANNA
body2023
DigiLaw.ai
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.