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2025 (7) TMI 261 - SCH - Income TaxValidity of reopening of assessment u/s 147 - Eligible income to be brought to tax - Delay filling SLP delay of 442 days - as decided by HC 2023 (11) TMI 544 - BOMBAY HIGH COURT if there was no reply filed by petitioner the onus is on department to justify the reopening. If one considers the material relied upon by respondents to reopen there are two buy and two sell. What has been brought has been sold or what has been sold only has been brought. Reassessment notice set aside HELD THAT - Having heard the learned Additional Solicitor General we see no reason to condone the inordinate delay of 442 days in filing the Special Leave Petition. Hence the Special Leave Petition stands dismissed on the ground of delay.
The Supreme Court, in a bench comprising Hon'ble Mr. Justice Pamidighantam Sri Narasimha and Hon'ble Mr. Justice R. Mahadevan, dismissed the Special Leave Petition due to an "inordinate delay of 442 days" in its filing. After hearing the Additional Solicitor General, the Court found "no reason to condone" this delay. Consequently, the petition was dismissed solely on the ground of delay, and all pending applications were disposed of.
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