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<h1>Reopening of assessment unsuitable where precedent favours taxpayer; excessive delay in filing SLP led to dismissal as time-barred.</h1> Reopening of assessment concerning disallowance of a cooperative-society deduction was contested where prior high-court precedent supported allowance of ... Reopening of assessment u/s 147 - Disallowance of deduction claimed u/s 80P (2) (d) - As decided by HC [2025 (1) TMI 817 - GUJARAT HIGH COURT] when the issue which is sought to be raised for disallowance of the deduction claimed by the assessee u/s 80P (2) (d) which is on the interest income earned by the petitioner from the fixed deposit kept with the Cooperative Bank is held in favour of the petitioner of this Court in case of Ashwinkumar Arban Co-operative Society Ltd. [2024 (11) TMI 971 - GUJARAT HIGH COURT] it cannot be said that this is a fit case to reopen the assessment in the facts of the case. Special leave petition has been filed 225 days beyond the period of limitation. HELD THAT:- Cause shown for condonation of delay is not sufficient. The application for condonation of delay to file the special leave petition stands rejected. Consequently, the special leave petition is dismissed as time-barred. Outcome: Special Leave Petition dismissed on the ground of time-barred.
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