Validity of reassessment proceedings challenged; excessive delay in filing SLP leads to dismissal with merits upheld

Challenge to validity of reassessment proceedings turned on sufficiency of reasons to believe and propriety of the reassessment; the High Court had quashed the reassessment notice and the objections rejection on merits. Separate issue concerned an inordinate 426-day delay in seeking special leave, with the explanation of departmental and administrative procedure found vague; no case for condonation of delay was made out, and the petition was dismissed on grounds of delay as well as on merits.

---

---

Issues: (i) Whether the delay of 426 days in filing the Special Leave Petition is liable to be condoned; (ii) Whether the High Court's judgment quashing the reassessment notice dated 31.03.2021 and the order rejecting objections is sustainable on merits.

Issue (i): Whether the inordinate delay of 426 days in filing the Special Leave Petition should be condoned.

Analysis: The delay of 426 days is attributed broadly to departmental and administrative procedure without specific or adequate explanation. The explanation provided is vague and insufficient to justify condonation under established principles permitting extension of time only on acceptable and particularised grounds.

Conclusion: In favour of Assessee. The delay is not condoned and the petition is dismissed on the ground of delay.

Issue (ii): Whether the High Court's quashing of the reassessment notice dated 31.03.2021 and the order rejecting objections is liable to interference on merits.

Analysis: The High Court's decision on the merits was examined and found to be supportable on its reasoning and factual and legal analysis. There is no persuasive basis in the Special Leave Petition to interfere with the High Court's view on merits.

Conclusion: In favour of Assessee. The High Court's quashing of the reassessment notice and related order is upheld.

Final Conclusion: The Special Leave Petition is dismissed both for failure to justify the delay and on the merits, leaving the High Court's decision quashing the reassessment notice intact.

Ratio Decidendi: An inordinate and unexplained delay in filing a Special Leave Petition is a ground for dismissal; where a High Court's merits-based quashing of a reassessment notice is supportable, the Supreme Court will not interfere.

---