Income-tax search assessments u/ss153A/153C for six years: challenge rejected as 448-day delayed SLPs dismissed The dominant issue was whether the challenge to the HC's interpretation of ss. 153A/153C of the Income-tax Act could be entertained despite an inordinate ...
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Income-tax search assessments u/ss153A/153C for six years: challenge rejected as 448-day delayed SLPs dismissed
The dominant issue was whether the challenge to the HC's interpretation of ss. 153A/153C of the Income-tax Act could be entertained despite an inordinate filing delay. The SC held that the Special Leave Petitions were barred by delay of 448 days and, on that basis alone, declined to exercise its discretionary jurisdiction under Art. 136, without adjudicating the merits of the controversy regarding assessment/reassessment for six AYs, "relevant assessment year," or the necessity of incriminating material and a valid satisfaction note. The Special Leave Petitions were dismissed as time-barred, and connected applications were disposed of.
The petitions suffered from "gross delay" in filing: 448 days for Special Leave Petition (Civil) Diary No. 64607/2025 and 474 days for Special Leave Petition (Civil) Dy. No. 67131/2025. The Court found that the delay "has not been satisfactorily explained by the petitioners." On that basis, "The Special Leave Petitions are, accordingly, dismissed on the ground of delay." Consequentially, "Pending applications, if any, also stand disposed of." The Court further directed that "All other matters be tagged with Diary No.55799/2024."
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