In Brief
The Supreme Court dismissed a Special Leave Petition filed by the Principal Commissioner of Income-tax against Seagram Manufacturing (P.) Ltd on the ground of delay. However, the Court held that dismissal on procedural grounds does not resolve the underlying legal question. The Court kept the substantive legal issue open, indicating that it may be raised and adjudicated in an appropriate future proceeding, thereby distinguishing between procedural dismissal and substantive resolution of the legal question.
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