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<h1>Failure to truly and fully disclose material facts questioned; petition dismissed for inordinate delay in filing the leave petition.</h1> Reopening of assessment under notice u/s 148 was contested on grounds that the proviso to Section 147 requires failure to truly and fully disclose ... Reopening of assessment - notice u/s 148 - proviso to Section 147 - failure to truly and fully disclose material facts - reasons to believe - change of opinion - HC held [2024 (8) TMI 364 - BOMBAY HIGH COURT] reasons recorded for reopening relied upon perceived discrepancies in the assessee's financials, alleged excess investment, claim of interest on borrowings, utilisation of securities premium, and adjustments under Rule 8D. The material in the reasons demonstrates scrutiny of the financial statements and differences of opinion rather than any failure by the assessee to truly and fully disclose material facts necessary for assessment. The reasons also indicate a change of opinion by the assessing officer - Delay in filling SLP HELD THAT:- No reason to condone the inordinate delay of 498 days in filing the Special Leave Petition as the explanation sought to be provided, does not constitute sufficient cause. Hence, the Special Leave Petition stands dismissed on the ground of delay. Outcome: Special Leave Petition dismissed on the ground of delay.
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