Extended limitation period and jurisdictional challenge in tax demand dismissed as raising no substantial question of law

Supreme Court review of an extended period of limitation and jurisdictional challenge concluded that the High Court correctly found no substantial question of law. The High Court treated the appellant's attempt as a reappraisal of factual findings aimed at delaying satisfaction of a demand, which does not convert mixed findings into a substantial legal question. Consequently, the challenge to jurisdiction and limitation did not permit interference with factual determinations, and the special leave petition was dismissed on that basis.

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The Supreme Court dismissed the special leave petition as no substantial question of law arose, concurring with the High Court's decision. Pending applications were also disposed of. (Case citation: TMI)

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