2025 (1) TMI 915 - SCH - Income Tax

Supreme Court dismisses petition citing 185-day delay and lack of satisfactory explanation; upholds High Court decision.

The SC dismissed the Special Leave Petition due to a 'gross delay of 185 days' in filing, which was not satisfactorily explained. The Court found no ... Validity of reopening of assessment - Reasons to believe - Delay filling SLP - as decided by HC [2024 (2) TMI 1506 - GUJARAT HIGH COURT] AO has mechanically recorded that the return was processed only u/s 143(1) of the Act which itself goes to suggest that recording of reasons at the instance of Assessing officer was nothing but in a mechanical manner and with no application of mind - HELD THAT:- There is a gross delay of 185 days in filing the Special Leave Petition which has not been satisfactorily explained by the petitioner. Even otherwise, we see no reason to interfere with the impugned order passed by the High Court. Special Leave Petition is, accordingly, dismissed on the ground of delay as well as on merits. The Supreme Court, presided over by Hon'ble Mr. Justice J. B. Pardiwala and Hon'ble Mr. Justice R. Mahadevan, dismissed the Special Leave Petition filed by the petitioner due to a 'gross delay of 185 days' in filing, which was 'not satisfactorily explained.' The Court also found 'no reason to interfere with the impugned order passed by the High Court.' Consequently, the petition was dismissed 'on the ground of delay as well as on merits,' and any pending applications were also disposed of.