Special leave petition dismissed; draft and final assessment orders barred by limitation under s.153(2A), no substantial question of law

SC dismissed the special leave petition, upholding the Tribunal's view-based on HC precedent-that both the draft and final assessment orders are barred by limitation under s.153(2A). The Court found no justification to interfere with the Tribunal's application of the principles concerning the scope of the word "received" and held the appeal did not raise any substantial question of law.

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"Delay condoned." The Court recorded that, after hearing counsel for the petitioner, it was "not inclined to entertain this special leave petition" and the "special leave petition is, accordingly, dismissed." The ruling therefore denies discretionary SLP relief sought by the petitioner, with no further substantive adjudication of the underlying merits. The Court also ordered that "Pending application(s), if any, shall stand disposed of." The decision reflects a procedural disposition: condonation of delay was granted, but the petition was rejected at the threshold for admission under Article 136, resulting in dismissal and termination of any attendant interim or ancillary applications.

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