Special Leave Petition dismissed for 237-day delay; trust entitled to s.11 exemption on full income, corpus and donations

SC dismissed the Special Leave Petition for a 237-day delay and on merits. The HC had upheld the Tribunal's decision that the assessee trust was entitled to exemption under s.11 for its entire income, including corpus and voluntary donations, and directed AO/CPC to delete adjustments made in the intimation u/s 143(1). The SC found the reasons for delay insufficient to condone and, on examination of the merits, found no substance to disturb the HC/Tribunal orders, thereby denying relief.

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There is a "delay of 237 days in filing the Special Leave Petition." The court holds that the "reasons assigned are neither satisfactory nor sufficient in law to condone the delay in filing the Special Leave Petition," and therefore the "application seeking condonation of delay is dismissed." On the merits, the court finds "nothing" in favour of the petitioner and accordingly the "Special Leave Petition is dismissed on the ground of delay as well as on merits." All pending application(s), if any, are directed to stand disposed of. The decision thus rests on both procedural grounds (failure to satisfy statutory/bench-tested standards for condonation of delay) and substantive assessment of the petition's merits, resulting in dismissal without granting leave to proceed.

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