Reassessment reopening u/s147: dispute over missing valid sanction claim raised late; appeal withdrawn to seek correction application

In a challenge to reassessment under s.147, the dominant issue before the SC was whether the petitioner could press a factual contention regarding absence of valid sanction when such contention was allegedly raised only in rejoinder and was not recorded or considered in the impugned HC judgment. The SC held that, since the impugned judgment did not reflect that the contention was agitated, any grievance that it was argued but not noted lay by way of an appropriate application before the HC. Consequently, the SLP was disposed of as withdrawn, leaving the petitioner to pursue relief before the HC.

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The Supreme Court allowed the petitioner to withdraw the Special Leave Petition to file an application before the High Court due to a factual contention not being considered in the impugned judgment.

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