2025 (2) TMI 500 - SCH - Income Tax

Validity of Reopening of assessment - reasons for reopening were examined at the time of original assessment - notice issued after expiry of more than four years - HC decided that 2024 (2) TMI 469 - BOMBAY HIGH COURT reasons recorded would show that there has been no failure on the part of Petitioner to truly and fully disclose material facts. Though the words failure on the part of assessee to disclose fully and truly all material facts necessary for assessment have been used in the reasons recorded those have been used only to get over the fetters placed by the proviso to Section 147 of the Act. HELD THAT - We are not inclined to interfere with the impugned judgment; hence the present special leave petition is dismissed. Pending application(s) if any shall stand disposed of.

Summary

The Supreme Court, with Hon'ble Chief Justice and Hon'ble Mr. Justice Sanjay Kumar presiding, dismissed the special leave petition after hearing counsel and condoning the delay. The Court declined to interfere with the impugned judgment, leading to the dismissal of the petition. Any pending applications were also disposed of accordingly.