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    <title>2025 (12) TMI 1234 - SC Order</title>
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    <description>The dominant issue was whether the challenge to the HC&#039;s interpretation of ss. 153A/153C of the Income-tax Act could be entertained despite an inordinate filing delay. The SC held that the Special Leave Petitions were barred by delay of 448 days and, on that basis alone, declined to exercise its discretionary jurisdiction under Art. 136, without adjudicating the merits of the controversy regarding assessment/reassessment for six AYs, &quot;relevant assessment year,&quot; or the necessity of incriminating material and a valid satisfaction note. The Special Leave Petitions were dismissed as time-barred, and connected applications were disposed of.</description>
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    <pubDate>Wed, 17 Dec 2025 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=783694</link>
      <description>The dominant issue was whether the challenge to the HC&#039;s interpretation of ss. 153A/153C of the Income-tax Act could be entertained despite an inordinate filing delay. The SC held that the Special Leave Petitions were barred by delay of 448 days and, on that basis alone, declined to exercise its discretionary jurisdiction under Art. 136, without adjudicating the merits of the controversy regarding assessment/reassessment for six AYs, &quot;relevant assessment year,&quot; or the necessity of incriminating material and a valid satisfaction note. The Special Leave Petitions were dismissed as time-barred, and connected applications were disposed of.</description>
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