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    <title>2025 (11) TMI 1680 - SC Order</title>
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    <description>SC dismissed the revenue&#039;s Special Leave Petition, which was delayed by 142 days, holding that the delay was not satisfactorily explained. On examining the impugned HC order, SC found no palpable error warranting interference. The HC had held that reopening of assessment u/s 147, even within four years, is impermissible when based solely on re-examination of the same material considered in the original assessment and absent any fresh tangible material. SC therefore declined to condone the delay and dismissed the petition both on the ground of limitation and on merits, leaving the HC decision undisturbed.</description>
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    <pubDate>Fri, 21 Nov 2025 00:00:00 +0530</pubDate>
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      <title>2025 (11) TMI 1680 - SC Order</title>
      <link>https://www.taxtmi.com/caselaws?id=782212</link>
      <description>SC dismissed the revenue&#039;s Special Leave Petition, which was delayed by 142 days, holding that the delay was not satisfactorily explained. On examining the impugned HC order, SC found no palpable error warranting interference. The HC had held that reopening of assessment u/s 147, even within four years, is impermissible when based solely on re-examination of the same material considered in the original assessment and absent any fresh tangible material. SC therefore declined to condone the delay and dismissed the petition both on the ground of limitation and on merits, leaving the HC decision undisturbed.</description>
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      <pubDate>Fri, 21 Nov 2025 00:00:00 +0530</pubDate>
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