2025 (8) TMI 390 - SCH - Income Tax

SC upholds dismissal of petition challenging reassessment under Section 148A(d) for unexplained share transactions

The SC dismissed the special leave petition challenging the validity of reassessment proceedings under section 148A(d) due to unexplained share ... Validity of reassessment proceedings - reasons to believe - Unexplained share transactions - delayed filling of SLP As decided by HC [2024 (9) TMI 148 - GUJARAT HIGH COURT] AO has failed to justify any of the reasons assigned to come to the conclusion that it is a fit case to reopen the assessment for the year under consideration. On perusal of the impugned order passed u/s 148A (d) of the Act, it is clear that the AO has arrived at conclusion to hold that it is a fit case to reopen only on the ground that the petitioner did not furnish the Sales and Purchase Register - HELD THAT:- We are not inclined to condone the delay or even to entertain the special leave petition on merits. Accordingly, the present petition stands dismissed on the ground of delay as well as on merits. The Supreme Court, through Hon'ble Justices Pankaj Mithal and Prasanna B. Varale, dismissed the petition due to a delay of 233 days in filing. After hearing counsel, the Court stated it was 'not inclined to condone the delay or even to entertain the special leave petition on merits.' Consequently, the petition was dismissed both on grounds of delay and merits, and all pending applications were disposed of.