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of <h1>Revenue petition dismissed for 183-day delay and meritless challenge to reopening assessment under Section 147</h1> The SC dismissed the revenue's Special Leave Petition, finding a 183-day unexplained delay in filing and concluding the petition lacked merit. The ... Reopening of assessment u/s 147 - reasons to believe or reason to suspect - escapement of income - delayed filing SLP by revenue HELD THAT:- There is a delay of 183 days in filing the Special Leave Petition which has not been satisfactorily explained. Even otherwise, we have gone through the Special Leave Petition and do not find any merit in the same. Special Leave Petition is, therefore, dismissed on the ground of delay as well as on merits. 'There is a delay of 183 days in filing the Special Leave Petition which has not been satisfactorily explained.' The Court reviewed the Special Leave Petition on both procedural and substantive bases, finding the delay unexplained and the petition lacking merit. Consequently, 'The Special Leave Petition is, therefore, dismissed on the ground of delay as well as on merits.' The judgment applies both laches/limitation principles (failure to justify the 183-day delay) and merits review (no substantive claim warranting relief). All pending application(s) connected to the petition were also disposed of. The order is a combined dismissal: procedural bar for inordinate and unexcused delay plus an independent merits conclusion negating entitlement to leave.
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