Special Leave Petition rejected for unexplained 454-day delay despite acceptance of eight industry comparables and direction to add more

ITAT's acceptance of the assessee's eight comparables for benchmarking royalty payments (same industry and geography) and direction to include additional valid comparables was noted, but the SC dismissed the Special Leave Petition for an unexplained 454-day delay in filing. The petition was therefore rejected on grounds of delay.

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There is a "gross delay of 454 days in filing the Special Leave Petition" which the petitioner/Revenue has not satisfactorily explained. On that basis the Court holds that the Special Leave Petition is, accordingly, "dismissed on the ground of delay." Pending applications, if any, are disposed of. The decision is procedural: the dismissal rests solely on inordinate delay and the absence of a satisfactory explanation rather than on the merits of the underlying dispute. The order treats unexplained delay as a jurisdictional and discretionary bar to entertain the petition, leading to summary disposal without adjudicating substantive issues.

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