Supreme Court dismisses petition challenging reassessment for fictitious capital loss claims due to 306-day filing delay

The SC dismissed a special leave petition challenging reassessment proceedings under section 147, where notice was issued under section 148A(b) alleging fictitious short-term capital loss claims. The HC had previously ruled that the notice failed to specify the basis for alleging the capital loss was fictitious, noting the petitioner invested based on public announcement and received tax-free dividends legitimately. However, the SC found no sufficient explanation for the 306-day delay in filing the petition and dismissed it solely on grounds of delay, without examining the merits of the reassessment challenge or the HC's findings regarding the inadequate notice.

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The Supreme Court, through Hon'ble Justices Manoj Misra and Ujjal Bhuyan, dismissed the special leave petition due to an unexplained delay of 306 days in filing. The Court held that the delay was not sufficiently justified, stating: "We do not find sufficient explanation for delay of 306 days in filing the special leave petition." Consequently, the petition was dismissed solely on the ground of delay.

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