2016 (4) TMI 1430 - SCH - Income Tax

Reopening of assessment u/s 147 - Reasons to believe - ATM is a computer or ought to be treated as normal plant and machinery, attracting different rates of depreciation - reason for reopening being merely a change of opinion on account of the assessment being made for the subsequent years would not give the AO the jurisdiction to reopen - HELD THAT - There is a delay of 234 days in filing this Special Leave Petition and we do not find any justifiable reason to condone this huge delay. Special Leave Petition is, accordingly, dismissed on the ground of delay. However, the question of law is kept open.

Summary

The Supreme Court dismissed the Special Leave Petition due to a delay of 234 days with no justifiable reason. The question of law remains open. (2016 (4) TMI 1430 - SC Order)