Supreme Court dismisses tax petitions with 322 and 358 day delays regarding Sections 153C and 148 assessment notices

The SC dismissed Special Leave Petitions filed with gross delays of 322 and 358 days respectively, which were not satisfactorily explained by petitioner. The case involved applicability of Sections 153C and 148 regarding reopening of assessment versus assessment in cases of seizure of material relating to assessee other than the searched person. The HC had quashed notices issued under Section 148 and related orders, holding that Section 153C does not preclude issuance of notice under Section 148, though the field of applicability of both sections was not directly at issue. The SC found no reason to interfere with the HC's common impugned order and dismissed the petitions on grounds of both delay and merits, while keeping the question of law open for future consideration.

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The Supreme Court, through Justices J. B. Pardiwala and R. Mahadevan, dismissed the Special Leave Petitions due to a "gross delay of 322 and 358 days" in filing, which was "not satisfactorily explained" by the petitioner. Additionally, the Court found "no good reason to interfere with the common impugned order passed by the High Court." The petitions were dismissed "on the ground of delay as well as merits," but the "question of law is kept open." Pending applications were also disposed of.

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