Special leave petition dismissed where reopening under section 147 relied on investigative material without fresh link to income escapement

SC dismissed the special leave petition, holding that the reasons recorded for reopening under section 147 were based on borrowed satisfaction from investigative information and did not disclose any live link or fresh material connecting the assessee's penny-share/stock transactions to escapement of income. The Court found the assessing officer assumed jurisdiction without independent application of mind; nevertheless, no interference under Article 136 was warranted and the SLP was dismissed, with pending applications disposed.

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The Supreme Court, exercising jurisdiction under Article 136 of the Constitution of India, dismissed the Special Leave Petition. The Court condoned the delay but found that "no case for interference is made out." Consequently, the petition was dismissed, and any pending applications were also disposed of. The order reflects the Court's discretion in granting special leave and underscores the principle that such interference is warranted only when substantial grounds exist, which were absent in this matter.

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