SLP on limitation u/s153(2A) dismissed, confirming draft and final assessment orders were time-barred for revenue

SC dismissed the revenue's SLP challenging the HC's decision on limitation under s.153(2A) regarding validity of the draft and final assessment orders. The petitioner-revenue conceded that an identical issue had already been decided against it in an earlier SC order, wherein a similar matter was dismissed. Relying on that precedent, SC declined to interfere and summarily dismissed the present SLP, thereby affirming the HC's view that the assessment orders in question were barred by limitation. No separate issue of condonation of delay arose for adjudication.

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The Court first condoned the delay in filing the Special Leave Petition (SLP), thereby treating the petition as properly before it on merits. Counsel for the petitioner informed the Court that a "similar matter has already been dismissed by this Court vide order dated 03.11.2025 in SLP(C) No. 31681/2025." Relying on the prior dismissal of the identically situated SLP, the Court declined to entertain the present petition. It held that, "In view thereof, the present Special Leave Petition also stands dismissed." No independent or distinct legal issue was identified that would justify a departure from the earlier decision in SLP(C) No. 31681/2025. As a consequence of the dismissal of the SLP, all pending interlocutory or ancillary applications in the matter were also brought to an end, the Court directing that "Pending application(s), if any, shall stand disposed of." The order thus rests on the principle of consistency with prior orders in substantially similar matters, without entering into a detailed examination of the merits.

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