Petition dismissed for 305-day inordinate delay; AO conducted full inquiry under Section 54B, Section 263 revision unjustified SC dismissed the Special Leave Petition for a 305-day delay, holding the delay inordinate and not sufficiently explained. The Tribunal had found that the ...
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Petition dismissed for 305-day inordinate delay; AO conducted full inquiry under Section 54B, Section 263 revision unjustified
SC dismissed the Special Leave Petition for a 305-day delay, holding the delay inordinate and not sufficiently explained. The Tribunal had found that the AO made full inquiry and examined conditions under section 54B as noted by the HC, and therefore the Commissioner's differing belief did not justify invoking revision under section 263. Consequently, the PCIT order under section 263 could not be sustained, and the petition was dismissed on the ground of delay.
Supreme Court of India; Citation: TMI. The Court declined to condone an "inordinate delay of 305 days" in filing the Special Leave Petition, finding the explanation offered did not constitute "sufficient cause." Consequently, the "petition(s) stands dismissed on the ground of delay." The order is a brief dismissal for procedural non-compliance rather than a merits adjudication; no submissions for the respondent were recorded. The decision reinforces the principle that unexplained or inadequately explained substantial delay in seeking special leave will attract summary dismissal, emphasizing strict adherence to limitation norms governing Special Leave Petitions.
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