Special Leave Petitions dismissed for inordinate delay; prior judgments disallowances upheld under s.40(a)(i) for s.195 TDS failures

SC dismissed the Special Leave Petitions for inordinate delay (411, 1,059 and 50 days) in filing/refiling, finding the delays unexplained and providing no sufficient reason to admit them. The court declined to interfere with the HC judgments upholding disallowance under s.40(a)(i) for non-deduction of TDS under s.195 on payments (including salary reimbursements and other expenditure) to a foreign entity. The SLPs were dismissed on the ground of delay.

---

---

"There is inordinate delay of 411, 1059 days/50 days in filing/refiling the Special Leave Petitions respectively which have not been satisfactorily explained." The Court notes the unexplained, substantial delays as the principal ground for refusal of relief. It also finds no substantive basis to disturb the High Court's determinations: "Even otherwise, we see no good reason to interfere with the impugned orders/judgment(s) of the High Court." Consequentially, "The Special Leave Petitions are, therefore, dismissed on the ground of delay." All pending applications are disposed of. The decision rests on procedural default (inordinate delay lacking satisfactory explanation) coupled with the absence of any compelling legal merit to justify interference with the High Court's rulings.

---