Special leave petitions dismissed for unexplained inordinate delay; Section 153C requires reasons linking seized material to assessed income

SC dismissed the Special Leave Petitions challenging the HC order, holding there was inordinate delay in filing the SLPs not satisfactorily explained. The Court upheld the HC's conclusion that the AO failed to record reasons showing how seized material bore on another person's total income under Section 153C, and rejected the respondents' approach that mere recovery of material automatically authorised assessment of the preceding six assessment years. No interference was warranted on delay or merits; SLPs dismissed.

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The Court found an "inordinate delay in filing the Special Leave Petitions which has not been satisfactorily explained by the petitioner." It further held that, "even otherwise, we see no good ground to interfere with the impugned order passed by the High Court." On both procedural and substantive bases, the petitions were dismissed: "The Special Leave Petitions are, therefore, dismissed on the ground of delay as well as merits." All pending applications were disposed of. The decision therefore rests on a twofold rationale: (1) procedural bar due to unexplained delay in seeking special leave, and (2) absence of any arguable merit warranting interference with the High Court's order. The dismissal disposes comprehensively of the matter before the Supreme Court.

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