Delay of 294 days invalidated SLP filing. Reopening assessment sans proper sanction u/s 151(1). ITO's satisfaction from non-competent authority.

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....Delay of 294 days in filing Special Leave Petition deemed invalid. Reopening of assessment u/s 143(3) without proper sanction u/s 151(1) from competent authority. Income Tax Officer obtained satisfaction from Additional Commissioner, an authority not covered by Section 151(1). Writ petition under Article 226 maintainable due to non-fulfillment of pre-conditions for exercise of power u/s 148. Application seeking condonation of delay dismissed by Supreme Court due to unsatisfactory explanation, consequently dismissing Special Leave Petition on ground of delay.....