Income-tax reassessment reopening beyond four years u/ss147/148 for missing disclosures-notices quashed; SLP dismissed for delay, merits.

Reassessment notices issued after completed assessments were challenged as lacking the statutory preconditions under ss. 147/148, IT Act, particularly the twin requirements of "reason to believe" and assessee's failure to disclose fully and truly all material facts where reopening is beyond four years. The HC held the AO lacked jurisdiction because the recorded reasons did not satisfy these conditions, and the Revenue could not cure the defect by filing additional affidavits or supplementing material beyond the recorded reasons; consequently, the notices and orders rejecting objections were quashed. In appeal, the SC dismissed the SLP due to an unexplained 501-day delay and, independently, declined interference on merits.

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The Special Leave Petition was filed with a "gross delay of 501 days," which "has not been satisfactorily explained by the petitioners." The petition was therefore dismissed on limitation. Independently, the Court held that "we are not inclined to interfere with the impugned order passed by the High Court," indicating no grounds for discretionary interference under Article 136. Accordingly, "The Special Leave Petition is, accordingly, dismissed on the ground of delay as well as on merits." Any pending applications were disposed of.

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