333-day delay in appeal against reopened tax assessment and s. 80CCC deduction dispute leads to dismissal for lack of cause The dominant issue was whether 'sufficient cause' was shown to condone an inordinate 333-day delay in filing the SLP challenging reopening of assessment ...
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333-day delay in appeal against reopened tax assessment and s. 80CCC deduction dispute leads to dismissal for lack of cause
The dominant issue was whether "sufficient cause" was shown to condone an inordinate 333-day delay in filing the SLP challenging reopening of assessment under s. 147 and deduction under s. 80CCC. Applying the strict standard for condonation, the SC held that the explanation offered did not constitute sufficient cause and therefore refused to condone the delay; consequently, the SLP was dismissed on the ground of delay, with the question of law kept open for consideration in an appropriate case.
The Supreme Court declined to condone an "inordinate delay of 333 days" in filing the Special Leave Petition, holding that "the explanation sought to be provided, does not constitute sufficient cause." On this procedural ground, the Court dismissed the petition without examining the merits. It expressly clarified that "the question of law is kept open for being considered in an appropriate case," indicating no adjudication on the underlying legal issue and preserving it for future determination. Consequently, "The Special Leave Petition stands dismissed on the ground of delay," and any pending applications were disposed of.
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