Condonation of Delay: unexplained inordinate delay barred review; no arguable error or miscarriage of justice found on merits.

Two issues were addressed: (i) condonation of a 237 day delay in filing the review petition - the Court applied principles of condonation of delay and laches, found the explanation unsatisfactory, and refused to extend time; outcome: delay not condoned. (ii) merits of the review - the Court applied the narrow scope of review, requiring demonstrable error or manifest injustice to reopen a final order, found no arguable ground to review the order dated 16.04.2025 in Civil Appeal No.1208 of 2025, and dismissed the petition on merits; outcome: review dismissed and interlocutory application disposed of.

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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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