2024 (12) TMI 326

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..... e Petition - As decided in HC [ 2017 (7) TMI 1010 - DELHI HIGH COURT] reopening of assessments after a period of four years, ought to be an exception and not the rule. The purpose of this provision is to ensure that there is some finality which is attached after the period of four years, for assessments which have been completed u/s 143 (3) - AO has to necessarily record that there has been a fail .....

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..... l as the learned counsel for the respondent on the said application and perused paragrpahs 4 and 5 of the affidavit filed in support of the application seeking condonation of delay. On the perusal of the same, we find that the reasons assigned are neither satisfactory nor sufficient in law so as to condone the delay of 457 days in filing the special leave petition. Hence, the application seeking c .....

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..... elay. 3. We have heard learned counsel for the petitioner as well as the learned counsel for the respondent on the said application and perused paragrpahs 4 and 5 of the affidavit filed in support of the application seeking condonation of delay. 4. On the perusal of the same, we find that the reasons assigned are neither satisfactory nor sufficient in law so as to condone the delay of 457 days in .....

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