TMI Blog2025 (1) TMI 289X X X X Extracts X X X X X X X X Extracts X X X X ..... amended provisions of the Income Tax Act - delay filling SLP - As decided by HC [ 2024 (4) TMI 1214 - GUJARAT HIGH COURT] on same material only because the year under consideration being A.Y. 2018-19 no scrutiny assessment is undertaken by AO and this being a new regime of reassessment after 1st April, 2021, no different treatment can be given for reopening only because the scope is enlarged by t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... v. Mr. Navanjay Mahapatra, Adv. Mr. Suyash Pandey , Adv ORDER UPON hearing the counsel the Court made the following. 1. Heard the learned Additional Solicitor General appearing for the petitioner - Revenue and gone through the materials on record. 2. There is a gross delay of 123 days in filing the Special Leave Petition which has not been satisfactorily explained by the petitioner. 3. Even otherw ..... X X X X Extracts X X X X X X X X Extracts X X X X
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