2025 (9) TMI 525 - SCH - Income Tax

Appellant's reassessment for omitted expenditure tax liability for 1994-95 to 1996-97 upheld; limitation not a bar

SC affirmed the HC's concurrent finding that reassessment proceedings were permissible because the appellant omitted and failed to disclose liability to ... Re-assessment proceedings - Whether the proposed action was barred by limitation? - As decided by HC [2013 (6) TMI 383 - HIMACHAL PRADESH HIGH COURT] the concurrent finding of fact is that it is a case of omission and failure of the appellant to disclose the liability to pay expenditure tax in respect of chargeable expenditure for the relevant period of assessment years 1994-95 to 1996-97. HELD THAT:- After hearing learned senior counsel appearing for the appellant and learned Additional Solicitor General for the respondent, we see no reason and ground to interfere with the impugned order passed by the High Court. Accordingly, the civil appeals are dismissed. Supreme Court reviewed interlocutory proceedings arising from a High Court order and, after hearing senior counsel for the parties, declined to disturb that order. The Court held that 'we see no reason and ground to interfere with the impugned order passed by the High Court.' Consequentially, the civil appeals were dismissed and all pending applications were directed to stand disposed of. The decision rests on the absence of any legally sufficient basis to upset the High Court's ruling rather than on re-examination of factual findings; no further substantive relief was granted. The disposition is summary and final as to the appeals and attendant interim applications.