Reassessment under ss.147/148 and notices under ss.148/148A quashed; delayed SLPs dismissed for gross unexplained delay

SC dismissed the SLPs for gross, unexplained delay and refused relief. The HC had held the petitions were covered by an earlier HC decision and the parties' counsel concurred; accordingly the reassessment initiated under ss.147/148 (and notices under ss.148/148A) was quashed and set aside. The court declined to entertain the delayed SLPs by Revenue on limitation grounds.

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There is a gross delay 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. The decision rests solely on procedural grounds of delay and insufficiency of explanation by the Revenue; no examination of merits was undertaken. The Court treated the unexplained delay as fatal to the petitions, resulting in dismissal of the SLPs and disposal of ancillary filings.

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