2024 (10) TMI 208 - SCH - Income Tax

Reopening of assessment - petitioner was a beneficiary of accommodation entries - Delay filling SLP - as decided by HC 2022 (12) TMI 1460 - GUJARAT HIGH COURT action of reopening by the AO was bad in law mainly for the reason that it was passed on a mere change of opinion on the same set of facts which was disclosed and considered by the assessing officer during previous AY - HELD THAT -There is gross delay of 489 days in filing this Special Leave Petition. The reasons assigned for explaining the said delay are neither satisfactory nor sufficient in law to be condoned. Hence the application seeking condonation of delay is dismissed. Consequently the Special Leave Petition also stands dismissed.

Summary

The Supreme Court dismissed the Special Leave Petition due to a gross delay of 489 days in filing, with reasons for the delay deemed unsatisfactory. The application seeking condonation of delay was also dismissed.