SLP Dismissed for 483-Day Delay; Revision under Section 263 Requires Error and Revenue Prejudice The SC dismissed the SLP as barred by limitation due to a 483-day delay in filing, rejecting the condonation application. The HC had held that for ...
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SLP Dismissed for 483-Day Delay; Revision under Section 263 Requires Error and Revenue Prejudice
The SC dismissed the SLP as barred by limitation due to a 483-day delay in filing, rejecting the condonation application. The HC had held that for invoking revision under Section 263, the AO's order must be both erroneous and prejudicial to revenue. Since the latter condition was not met, the appeal was disposed of based on the statement made by the appellant.
The Supreme Court examined a Special Leave Petition accompanied by a condonation application seeking to excuse a delay of 483 days. After hearing the parties, the Court found the explanation for the delay insufficient and thus rejected the condonation application. Consequently, the Special Leave Petition was dismissed as barred by limitation. All pending applications related to the matter were disposed of. The Court emphasized adherence to strict limitation periods, underscoring that unexplained or excessive delays cannot be condoned.
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