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of <h1>Special leave petition dismissed for delay and on merits; revision under section 263 unwarranted; original assessment upheld</h1> <h3>Principal Commissioner of Income Tax 3 Versus Reckitt Benckiser Healthcare India Pvt. Ltd.</h3> The SC dismissed the special leave petition both for delay and on merits, upholding the HC's view that the Principal CIT's mere opinion that the assessing ... Revision u/s 263 - HC [2023 (12) TMI 1470 - GUJARAT HIGH COURT] held merely because the Principal CIT, on perusal of record, is of the opinion that estimate made by the concerned AO was inadequate and the assessment order cannot be said to be erroneous and prejudicial to the interest of the Revenue - HELD THAT:- Special Leave Petition is dismissed on ground of delay as well as on merits. The Court stated it did not find 'a good reason to condone the reported delay.' The Special Leave Petition was 'dismissed on ground of delay as well as on merits.' Consequently, no relief was granted on either procedural or substantive bases. All ancillary or interlocutory proceedings attaching to the petition were terminated, as 'Pending application(s), if any, shall stand disposed of.' The order reflects the dual disposition principle: failure to satisfy the jurisdictional threshold for condonation of delay independently defeats maintainability, and the petition was further negatived on substantive merits. No directions or remittal were issued, and no extension of limitation was permitted. The concise order operates as a final adjudication on both procedural (limitation/condonation) and substantive fronts.
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