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        Case ID :

        2026 (2) TMI 885 - SCH - Income Tax

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        Delay in filing bars relief: petition dismissed for delay and no further software-direction modifications required. The petition was dismissed primarily because the court refused to condone a 360 day delay, applying the principle that unexplained or unpersuaded delay ...
                      Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
                        Provisions expressly mentioned in the judgment/order text.

                            Delay in filing bars relief: petition dismissed for delay and no further software-direction modifications required.

                            The petition was dismissed primarily because the court refused to condone a 360 day delay, applying the principle that unexplained or unpersuaded delay bars entertainment of relief; condonation was denied and the petition dismissed on that ground. Separately, the court found no need to vary prior clarified directions concerning required software modifications, stating the existing directions are sufficient and no additional orders or relief are warranted; the petition was therefore also dismissed on the merits insofar as no further software-related relief was necessary.




                            Issues: (i) Whether the Special Leave Petition should be entertained despite a delay of 360 days in filing; (ii) Whether any further relief or modification is required in view of this Court's earlier order clarifying directions given with reference to changes to be made in the software.

                            Issue (i): Whether the petition is barred by delay of 360 days and whether condonation should be granted.

                            Analysis: The petition record shows a delay of 360 days. The petitioners did not persuade this Court to overlook the delay. The petition was considered in the factual context of earlier intervening orders addressing similar issues.

                            Conclusion: The petition is dismissed on the ground of delay; condonation of delay is not granted.

                            Issue (ii): Whether further orders are required in light of this Court's earlier directions regarding changes to the software.

                            Analysis: This Court's earlier order in Civil Appeal No. 197 of 2026 dated 12th January, 2026 clarified the directions concerning software modifications. The present petition does not require additional directions beyond those already issued.

                            Conclusion: No further orders are necessary; the petition is dismissed on merits insofar as no additional relief is warranted.

                            Final Conclusion: The Special Leave Petition is dismissed both for delay and on merits, with no further directions required in view of the prior clarification of software-related directions by this Court.


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                            ActsIncome Tax
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