Commissioner Of Income-Tax And Ors. vs Data Software Research Co. Ltd.

The Supreme Court held that the High Court erred in condoning the delay in the production of agreements under Section 80-O of the Income-tax Act, 1961, as there is no provision for such condonation. The Court emphasized that the requirement to produce agreements before October 1 of the assessment year is mandatory and cannot be overlooked. The appeal by the Revenue was allowed, and the High Court's order was set aside, allowing the respondent to apply to the Central Board of Direct Taxes for condonation of delay if desired.