2025 (5) TMI 837 - SCH - Income Tax

Validity of reopening of assessment - Reasons to believe - addition u/s 68 - whether the notice issued u/s 148 and the order passed disposing of the objection can be said to be legal in eye of law? - HC 2024 (2) TMI 1506 - GUJARAT HIGH COURT reopening on the basis of the same details is nothing but change of opinion and the same is not permissible in the eye of law thus decided in favour of assessee. HELD THAT - There is a gross delay of 308 days in filing the present Special Leave Petition which has not been satisfactorily explained by the petitioner. Even otherwise we see no reason to interfere with the impugned order passed by the High Court. Special Leave Petition is dismissed on the ground of delay as well as on merits.

Summary

The Supreme Court, through Justices J.B. Pardiwala and R. Mahadevan, dismissed the Special Leave Petition due to a "gross delay of 308 days" in filing, which was "not satisfactorily explained" by the petitioner. Additionally, the Court found "no reason to interfere with the impugned order passed by the High Court." Consequently, the petition was dismissed both "on the ground of delay as well as on merits," and all pending applications were disposed of.