2024 (7) TMI 853 - SCH - Income Tax

Delay filling SLP - Validity of reopening of assessment u/s 147 - Notice beyond the period of 4 years - HC 2023 (1) TMI 1391 - GUJARAT HIGH COURT decided reasons recorded for reopening were based on the same facts already scrutinized indicating a mere change of opinion by the Assessing Officer - HELD THAT - There is a delay of 400 days in the filing of the present special leave petition. Even on merits we are not inclined to interfere with the impugned judgment. Recording the aforesaid the application for condonation of delay and consequently the special leave petition are dismissed.

Summary

The Supreme Court dismissed the special leave petition due to a 400-day delay in filing and declined to interfere with the impugned judgment. The application for condonation of delay was also dismissed.