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2025 (7) TMI 1244 - SCH - Income TaxReopening of assessment u/s 147 - notice issued u/s 148A(b) as alleged that petitioner was one of the persons who claimed fictitious short-term capital loss - delay of 306 days in filing the SLP - As decided by HC 2024 (3) TMI 953 - BOMBAY HIGH COURT there is nothing in the notice to indicate on what basis it is alleged that the short-term capital loss claimed was fictitious. Petitioner had based on public announcement invested in the mutual fund. The fact that petitioner received tax free dividend fund cannot be held against petitioner - HELD THAT - We do not find sufficient explanation for delay of 306 days in filing the special leave petition. The special leave petition is accordingly dismissed on the ground of delay. The Supreme Court, through Hon'ble Justices Manoj Misra and Ujjal Bhuyan, dismissed the special leave petition due to an unexplained delay of 306 days in filing. The Court held that the delay was not sufficiently justified, stating: "We do not find sufficient explanation for delay of 306 days in filing the special leave petition." Consequently, the petition was dismissed solely on the ground of delay.
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