2026 (3) TMI 497 - SCH - Income Tax

Obligation to Make Submissions: petitioner must appear before AO, furnish information and make full submissions; discretionary review refused.

Challenge concerned validity of reopening an assessment where the petitioner delayed responding and had sought time to reply but did not furnish ... Validity of reopening of assessment - Obligation to make submissions before the AO - petitioner's requests for time to reply, the filing of a delayed reply - AO to consider submissions and proceed in accordance with law As decided by HC petition was filed after a considerable lapse of time of one and half years from the order, that the petitioner had sought time to reply and had not furnished the information sought under Section 142(1). Given these facts and the nature of the controversy, the Court declined to decide the substantive validity of the notices and order. Instead, the petitioner was directed to appear before the Assessing Officer, make full factual and legal submissions and furnish the information called for HELD THAT:- We do not find a good ground to interfere with the impugned order/judgment in exercise of our jurisdiction under Article 136 of the Constitution of India. Accordingly, the special leave petition stands dismissed. Outcome: Special Leave Petition dismissed [No detailed order].