PCIT v. Suncity Projects Pvt. Ltd. (2022) 448 ITR 717 /(2023) 290 Taxman 374/ 330 CTR 623/ 222 DTR 191 (SC)

S. 260A : Appeal-High Court-Limitation-Delay of 86 days-Delay was condoned-High Court directed to dispose of appeals on merits.

Allowing the appeal the Court held that the High Court ought to have condoned the delay of 86 days in preferring the appeals and ought not to have been too technical in dismissing the appeals on the ground of delay. The order of the High Court was unsustainable. [The delay of 86 days in filing the appeals was condoned and the High Court was to decide and dispose of the appeals in accordance with law and on the merits. It would be open for the assessee to submit before the High Court that it had settled the dispute under the Direct Taxes Vivad Se Vishwas Scheme and the High Court would consider the consequences of any settlement under the Scheme in accordance with law and on its own merits.