SC upholds Section 153C(1) proviso applies to limitation period and abatement; review petition dismissed for delay and merits The SC dismissed the review petition filed after a 433-day delay challenging the previous order upholding the interpretation of Section 153C(1). The Court ...
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SC upholds Section 153C(1) proviso applies to limitation period and abatement; review petition dismissed for delay and merits
The SC dismissed the review petition filed after a 433-day delay challenging the previous order upholding the interpretation of Section 153C(1). The Court affirmed that the proviso to Section 153C(1) addresses not only abatement but also the commencement date for the six-year limitation period for filing returns by third parties whose premises were not searched. The revenue's contention limiting the proviso's scope to abatement was rejected. Upon examination, the SC found no grounds warranting review and dismissed the petition both for delay and on merits.
The Supreme Court, presided over by Hon'ble Mr. Justice J.B. Pardiwala and Hon'ble Mr. Justice Aravind Kumar, addressed a review petition with a "gross delay of 433 days" in its filing. The petitioner sought a review of the Order dated 26th September 2023, which dismissed the original Civil Appeal. Upon examination of the Order and the record, the Court found that "no case for review is made out." The review petition was dismissed both on the grounds of delay and on its merits.
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