SC rejects delay condonation in SLP against reopening assessment under Section 147 for undisclosed income from trading

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....The SC dismissed the petition seeking condonation of a 196-day delay in filing the SLP, finding no sufficient grounds to excuse the delay. The petitioner's challenge pertained to the reopening of assessment under section 147 based on alleged undisclosed income from trading in Kusha Script on BSE. The AO's reasons recorded lacked detailed information beyond the non-genuine gain assertion. The Court noted that even if the proposed addition was accepted, the income taxed under section 115JB would eliminate any further taxable income, rendering reassessment futile. Consequently, the petition was dismissed on delay grounds, and the reassessment proceedings were effectively quashed as continuing them would serve no useful purpose.....