2024 (11) TMI 1165 - SCH - Income Tax

Validity of Reopening of assessment u/s 147 - no Valid approval u/s 151 - as argued notice issued u/s 148 was wholly without jurisdiction as it does not meet the pre-requisite conditions stipulated under the amended scheme of reassessment - also approval granted u/s 151 by the specified authority reflects non application of mind - delay filling SLP As decided by HC 2023 (8) TMI 519 - BOMBAY HIGH COURT AS considered the approval u/s 151 we are satisfied that there is no valid sanction. There is no evidence that PCIT has even granted any valid sanction. HELD THAT - There is a delay of 351 days in filing the Special Leave Petition which has not been satisfactorily explained. Even otherwise, we have gone through the Special Leave Petition and do not find any merit in the same. Special Leave Petition is, therefore, dismissed on the ground of delay as well as on merits.

Summary

The Supreme Court dismissed the Special Leave Petition due to a delay of 351 days in filing and lack of merit in the petition. Pending applications were disposed of. Key persons involved were Mr. N Venkatraman, Mr. Rupesh Kumar, Mr. Raj Bahadur Yadav, Mr. Udai Khanna, Mr. Sarthak Karol, Mr. Chitvan Singhal, and Mr. Santosh Kumar.