2024 (9) TMI 658 - SCH - Income Tax

Delay in filling SLP - Validity of reopening of assessment - notice after a period of four years from the end of the relevant assessment year - agricultural income which included the long term capital gain arising out of the land in question as unexplained - as decided by HC 2022 (7) TMI 1536 - GUJARAT HIGH COURT entire premise for reopening of the assessment that the petitioner has failed to disclose the long term capital gain by filing return of income is without any basis.AO has failed to establish any live nexus between the material relied upon to reopen the assessment HELD THAT - We have heard learned senior counsel for the petitioner and also perused the application seeking condonation of delay. The reasons assigned for the delay are neither satisfactory nor sufficient in law to condone the same. Hence, the application stands dismissed. Consequently, the Special Leave Petition also stands dismissed on the ground of delay.

Summary

The Supreme Court dismissed a Special Leave Petition due to a gross delay of 648 days in filing, with the reasons for the delay deemed unsatisfactory. The application for condonation of delay was also dismissed.