2025 (2) TMI 924 - SCH - Income Tax

Penalty u/s 271(1)(c) - defective notice u/s 274 - non specification of clear charge/Default - HC decided 2023 (8) TMI 1373 - DELHI HIGH COURT Revenue does not dispute that none of the penalty notices issued to the respondent/assessee for the aforementioned AYs advert to the specific limb of Section 271(1)(c) which is triggered against him. It is not clear whether the AO intended to levy a penalty on the respondent/assessee for concealment of particulars of his income or furnishing inaccurate particulars. HELD THAT - There is gross delay of 371 days in filing this Special Leave Petition. Delay in refiling is condoned. Following the orders passed by this Court in 2024 (9) TMI 1698 - SC ORDER 2024 (9) TMI 1698 - SC ORDER and 2024 (7) TMI 975 - SC ORDER in the case of the very same respondent-assessee we dismiss the application seeking condonation of delay. Consequently the Special Leave Petition also stands dismissed.

Summary

The Supreme Court, in a judgement by Hon'ble Mrs. Justice B. V. Nagarathna and Hon'ble Mr. Justice Satish Chandra Sharma, noted a gross delay of 371 days in filing a Special Leave Petition. The delay in refiling was condoned. Referring to previous orders in similar cases, the Court dismissed the application seeking condonation of delay, leading to the dismissal of the Special Leave Petition. Any pending applications were disposed of accordingly.