2025 (3) TMI 537 - SCH - Income Tax

Reopening of assessment u/s 147 - Reason to believe - information received from the Investigation Officer Kolhapur that Petitioner made some cash deposit by assessee-trust - as decided by HC 2024 (3) TMI 954 - BOMBAY HIGH COURT no live link which is a sine qua non between the material before the AO in the present case and the belief which he has to form regarding escapement of income. The sanction u/s 151 of the Act granted by the prescribed authority as well as the notice is issued by the Department without any application of mind. Decided in favour of assessee. HELD THAT - There is a gross delay of 246 days in filing the Special Leave Petition which has not been satisfactorily explained by the petitioner. Special Leave Petition is accordingly dismissed on the ground of delay.

Summary

The Supreme Court, presided over by Hon'ble Justices J. B. Pardiwala and R. Mahadevan, dismissed the Special Leave Petition filed by the petitioner due to a "gross delay of 246 days" in filing, which was "not satisfactorily explained." The dismissal was based on the ground of delay. All pending applications related to the case were also disposed of.