State Cannot ‘Carve Out Its Own Limitation Period’: Supreme Court Dismisses Income Tax Dept’s Time-Barred SLP against Shriram Finance [Read Judgement]
The Court ruled that such lengthy inaction cannot be justified by depending only on internal approvals or administrative processes, especially if statutory timelines are specifically imposed by law.
![State Cannot ‘Carve Out Its Own Limitation Period’: Supreme Court Dismisses Income Tax Dept’s Time-Barred SLP against Shriram Finance [Read Judgement]](https://images.taxscan.in/h-upload/2025/12/16/2112651-state-carve-out-limitation-period-supreme-court-dismisses-income-tax-depts-slp-shriram-finance-taxscan.webp "State Cannot ‘Carve Out Its Own Limitation Period’: Supreme Court Dismisses Income Tax Dept’s Time-Barred SLP against Shriram Finance [Read Judgement]")
The Supreme Court has dismissed time-barred Special Leave Petitions (SLPs) filed by the Income Tax Department against a famous finance company, stating that the State cannot “carve out its own limitation period” by seeking indulgence for administrative delay . The SLPs were filed by the income tax department challenging the judgment of the Madras High Court dated 30 June 2022...
The Supreme Court has dismissed time-barred Special Leave Petitions (SLPs) filed by the Income Tax Department against a famous finance company, stating that the State cannot “carve out its own limitation period” by seeking indulgence for administrative delay .
The SLPs were filed by the income tax department challenging the judgment of the Madras High Court dated 30 June 2022 in TCA No. 360 of 2014 against Shriram City Union Finance Co. Ltd.
However, when the matters came up before the Supreme Court, the Registry reported an extraordinary delay of 892 days and 911 days, respectively, in filing the petitions. The Income Tax Department sought condonation of delay through interlocutory applications, mentioning the administrative issues.
After going over the Department's explanations, a bench made up of Justices Manoj Misra and Ujjal Bhuyan concluded that they were completely unsatisfactory. The Court ruled that such lengthy inaction cannot be justified by depending only on internal approvals or administrative processes, especially if statutory timelines are specifically imposed by law.
Additionally, the apex Court noted the decision in Shivamma (Dead) by LRs v. Karnataka Housing Board], where it was observed that State authorities and their instrumentalities are not entitled to special or extra leniency in matters of limitation.
The Court mentioned that government departments often showed a “lethargic and negligent attitude”, trying to create their own timelines with little regard for statutory limitation periods, a practice that cannot be judicially supported.
While upholding the equality before the law, the Bench made it clear that limitation statutes apply with equal force to private litigants and the State alike.
Consequently, the Supreme Court rejected the applications seeking condonation of delay and dismissed the Income Tax Department’s SLPs solely on the ground of limitation, without examining the merits of the tax dispute. All pending applications were also disposed of accordingly.
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