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Issues: (i) Whether the delay of 237 days in filing the Review Petition can be condoned; (ii) Whether the Review Petition merits interference with the earlier order.
Issue (i): Whether the delay of 237 days in filing the Review Petition can be condoned.
Analysis: The Court examined the applicant's explanation for delay and found it unsatisfactory. The petition was considered despite the admitted delay, but the reasons provided did not justify condonation under the governing principles for extension of time and laches applicable to review proceedings.
Conclusion: Delay not condoned; decision adverse to the Revenue and favourable to the assessee.
Issue (ii): Whether the Review Petition merits interference with the earlier order.
Analysis: On consideration of the Review Petition on merits, the Court found no arguable ground to reopen or review the order dated 16.04.2025 in Civil Appeal No.1208 of 2025, applying the narrow scope of review and the requirement of demonstrable error or miscarriage of justice for review relief.
Conclusion: No case made out for review; review petition dismissed on merits; decision adverse to the Revenue and favourable to the assessee.
Final Conclusion: The Review Petition is dismissed both on the ground of unexplained delay and on merits, and any pending interlocutory application is disposed of.
Ratio Decidendi: A review petition will not be entertained where there is unexplained, inordinate delay and where no arguable error or manifest injustice is shown to justify reopening a final order.
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