2024 (9) TMI 30 - SCH - Income Tax

Reopening of assessment u/s 147 - change of opinion - Delay in filling SLP - as decided by HC 2022 (7) TMI 1338 - ORISSA HIGH COURT Mere change of opinion on the same materials, set aside the reassessment notice and the consequential assessment order by its judgment - HC 2022 (7) TMI 1338 - ORISSA HIGH COURT quashes the notice issued to the Petitioner u/s 148 and the consequential order of the NAFAC rejecting the objections of the Petitioner to the reopening of the assessment. HELD THAT - There is a delay of 558 days in filing the Special Leave Petition which has not been satisfactorily explained. Special Leave Petition is dismissed on the ground of limitation.