Petitions dismissed for want of prosecution delay; dispute over reopening AY2014-15 assessment, limitation under s.148A(b) and s.149(1) proviso The SC dismissed the Special Leave Petitions filed by the revenue for want of prosecution delay (800 and 467 days) after holding the delays were not ...
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Petitions dismissed for want of prosecution delay; dispute over reopening AY2014-15 assessment, limitation under s.148A(b) and s.149(1) proviso
The SC dismissed the Special Leave Petitions filed by the revenue for want of prosecution delay (800 and 467 days) after holding the delays were not satisfactorily explained. The underlying dispute concerned validity of reopening an assessment for AY 2014-15, limitation for issuing notice under s.148A(b), the first proviso to s.149(1) and scope of the TOLA Act, 2022; the HC had earlier found the reopening barred by limitation and allowed the taxpayer's petition, but the SC did not reach merits due to delay.
There is a gross delay of 800 and 467 days respectively in filing the Special Leave Petitions which has not been satisfactorily explained by the petitioners - Revenue. The Special Leave Petitions are, accordingly, "dismissed on the ground of delay." Pending applications, if any, also stand disposed of.
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