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of <h1>Special leave petition dismissed for unexplained 411-day delay; merits lacking, earlier order quashing reopening of assessment upheld</h1> The SC dismissed the Special Leave Petition, finding an unexplained 411-day delay and no merit to disturb the High Court's order that had set aside the ... Validity of reopening of assessment - approval u/s 151 - period of limitation - three years after the expiry of assessment year - time limit for current proceedings - HC [2024 (4) TMI 1319 - BOMBAY HIGH COURT] set aside reopening proceedings - HELD THAT:- There is a gross delay of 411 days in filing the Special Leave Petition which has not been satisfactorily explained by the petitioner. Even otherwise, we see no good ground to interfere with the impugned order passed by the High Court. The Special Leave Petition is, therefore, dismissed on the ground of delay as well as merits. There is a 'gross delay of 411 days' in filing the Special Leave Petition which has not been satisfactorily explained by the petitioner. The Court further held that, 'even otherwise, we see no good ground to interfere with the impugned order passed by the High Court.' On those bases the petition was dismissed: 'The Special Leave Petition is, therefore, dismissed on the ground of delay as well as merits.' Pending application(s), if any, were disposed of. The disposition rests on two independent rationales: procedural infirmity for inordinate unexplained delay and substantive lack of merit in the challenge to the High Court order, rendering interference unjustified.
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