Reassessment notice upheld despite prior invalidation for 'borrowed satisfaction'; special leave dismissed after 142-day filing delay HC found the reassessment notice invalid for being issued on 'borrowed satisfaction' from a superior, concluding the AO did not apply his own mind. SC ...
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Reassessment notice upheld despite prior invalidation for "borrowed satisfaction"; special leave dismissed after 142-day filing delay
HC found the reassessment notice invalid for being issued on "borrowed satisfaction" from a superior, concluding the AO did not apply his own mind. SC noted a 142-day delay in filing the SLP but heard merits nonetheless and found no substance in the challenge. The Special Leave Petition was dismissed.
"Though there is delay of 142 days in filing this Special Leave Petition, we nevertheless have heard learned counsel for the petitioners on the merits of the case also." After consideration on merits, the Court held: "We do not find any merit in the Special Leave Petition." Accordingly, "the Special Leave Petition is dismissed." The application seeking condonation of delay is disposed of. All pending application(s), if any, stand disposed of. No substantive reasons beyond the brief observations on delay and merit are recorded.
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