2025 (2) TMI 777 - SCH - Income Tax

Reopening of assessmnet u/s 147 - reason to believe OR reason to suspect - delay filling SLP As decided by HC 2023 (2) TMI 426 - BOMBAY HIGH COURT Reasons recorded do not suggest at all whether pursuant to receipt of information the assessing Officer had independently applied its mind to the information received or conducted its own inquiry into the matter for the purpose of coming to a conclusion that indeed income assessable to tax had escaped assessment or that the transaction in question with the alleged shell entity was only a paper transaction HELD THAT - There is a delay of 354 days in filing the present special leave petition which has not been adequately and satisfactorily explained. Even on merits we do not see any good ground and reason 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 of India dismissed the special leave petition due to a delay of 354 days in filing, which was not adequately explained. The Court found no good ground to interfere with the impugned judgment. As a result, the application for condonation of delay and the special leave petition were both dismissed. Any pending applications were also disposed of.