Section 148 Cannot Bypass Section 153C Search Assessment Framework: SC

ACIT & Anr. Vs Gopal Prasad Gupta (Supreme Court of India)

The Supreme Court considered a Special Leave Petition filed by the Revenue challenging a High Court judgment that had quashed reassessment proceedings initiated under Section 148 of the Income Tax Act, 1961. The Supreme Court noted a gross delay of 560 days in filing the Special Leave Petition, which was not satisfactorily explained. It further held that even on merits, no interference with the High Court’s order was warranted. Accordingly, the Special Leave Petition was dismissed on the grounds of both delay and lac

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