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<h1>SC dismissed the special leave petition due to a delay of 316 days in filing and on its merits.</h1> SC dismissed the special leave petition due to a delay of 316 days in filing and on its merits. - TMI Revision u/s 263 - non-service of notice as agitated in first round of litigation - Tribunal confirmed gross violation of principles of natural justice deciding issue in favour of assessee - as decided by HC [second round] revenue seeks to convert HC as if it is a second appellate Court over the findings of the tribunal, thus no substantial question of law arises - HELD THAT:- There is delay of 316 days in filing the special leave petition. We find no merit to interfere with the judgment and order impugned in this petition. The Supreme Court dismissed the special leave petition due to a delay of 316 days in filing it. The petition was also dismissed on its merits.