Supreme Court Dismisses 411-Day Delayed SLP, No Interference with HC Ruling Quashing Income Tax Notice Issued 6 Years from A.Y. [Read Judgement]
The Apex Court dismissed the Revenue’s SLP on the grounds of limitation as well as on merits.
![Supreme Court Dismisses 411-Day Delayed SLP, No Interference with HC Ruling Quashing Income Tax Notice Issued 6 Years from A.Y. [Read Judgement]](https://images.taxscan.in/h-upload/2026/04/08/2132498-supreme-court-dismisses-411-day-delayed-slp-no-interference-with-hc-ruling-quashing-income-tax-notice-issued-6-years-from-ay-site-imagejpg.webp "Supreme Court Dismisses 411-Day Delayed SLP, No Interference with HC Ruling Quashing Income Tax Notice Issued 6 Years from A.Y. [Read Judgement]")
The Supreme Court of India recently dismissed a Special Leave Petition (SLP) filed by the Income Tax Department with a delay of 411 days, refusing to condone the delay or interfere with the impugned Delhi High Court ruling by which an income tax notice issued after a period of 6 years from the relevant Assessment Year (A.Y.) was quashed. In the earlier matter before the Delhi...
The Supreme Court of India recently dismissed a Special Leave Petition (SLP) filed by the Income Tax Department with a delay of 411 days, refusing to condone the delay or interfere with the impugned Delhi High Court ruling by which an income tax notice issued after a period of 6 years from the relevant Assessment Year (A.Y.) was quashed.
In the earlier matter before the Delhi High Court, the respondent herein - Wave Silver Tower Private Limited impugned an income tax order issued under Section 148 of the Income Tax Act, 1961 for A.Y. 2016-17, contending that the same had been issued beyond the permissible period of limitation.
The petitioner-assessee argued that the Revenue could not invoke reassessment powers in a manner that defeats the limitation safeguards prescribed under the statute, even referring to the decision of the Supreme Court in Union of India & Others v. Rajeev Bansal (2024).
The Delhi High Court bench comprising Justice Vibhu Bakhru and Justice Swarana Kanta Sharma noted that the period of six years for the relevant AY 2016- 17 had expired on 31.03.2022 and that the impugned notice was thus barred by limitation.
The Delhi High Court accordingly allowed the writ petition and quashed the impugned notice issued under Section 148 of the Act.
The Revenue, being aggrieved by the said ruling, preferred the present Special Leave Petition before the Supreme Court, albeit with a delay of 411 days.
The Supreme Court Bench comprising Justice J.B. Pardiwala and Justice K.V. Viswanathan noted that the delay had not been satisfactorily explained by the Revenue. The Court observed that there was a gross delay in filing the Special Leave Petition and declined to condone the same.
The Court further observed that even on merits, there was no ground to interfere with the impugned order passed by the Delhi High Court. Accordingly, the Special Leave Petition was dismissed on the ground of delay as well as on merits.
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