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    <title>2025 (11) TMI 1257 - SC Order</title>
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    <description>SC dismissed the revenue&#039;s Special Leave Petition challenging the HC order quashing reassessment proceedings u/s 147. The petition suffered from a delay of 198 days, which was not satisfactorily explained. On merits, SC found no ground to interfere with the HC&#039;s view that the share capital and premium received from a foreign investor had already been examined and accepted in assessments/reassessments u/s 143(3) in subsequent years. Since the nature and source of receipts were duly explained and not contradicted by the AO, reassessment was unjustified.</description>
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      <link>https://www.taxtmi.com/caselaws?id=781789</link>
      <description>SC dismissed the revenue&#039;s Special Leave Petition challenging the HC order quashing reassessment proceedings u/s 147. The petition suffered from a delay of 198 days, which was not satisfactorily explained. On merits, SC found no ground to interfere with the HC&#039;s view that the share capital and premium received from a foreign investor had already been examined and accepted in assessments/reassessments u/s 143(3) in subsequent years. Since the nature and source of receipts were duly explained and not contradicted by the AO, reassessment was unjustified.</description>
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