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    <title>2025 (12) TMI 1434 - SC Order</title>
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    <description>The dominant issue was whether gross delay in filing the special leave petition should be condoned. The SC held that the reasons advanced for condonation were neither satisfactory nor legally sufficient to justify exercise of discretion. Consequently, the application for condonation of delay was dismissed, and the special leave petition was dismissed as not entertainable, leaving undisturbed the HC&#039;s view that reassessment under s.147 was impermissible where the recorded reasons showed tax payable would be less than that already assessed under s.143(3), negating any belief of income escaping assessment.</description>
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    <pubDate>Mon, 08 Dec 2025 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=783894</link>
      <description>The dominant issue was whether gross delay in filing the special leave petition should be condoned. The SC held that the reasons advanced for condonation were neither satisfactory nor legally sufficient to justify exercise of discretion. Consequently, the application for condonation of delay was dismissed, and the special leave petition was dismissed as not entertainable, leaving undisturbed the HC&#039;s view that reassessment under s.147 was impermissible where the recorded reasons showed tax payable would be less than that already assessed under s.143(3), negating any belief of income escaping assessment.</description>
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