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Corporate TaxArticle·23 March 2026

Delay Defeats Merit

By J the App

Executive Summary

In a brief yet decisive order, the Supreme Court has reiterated a fundamental principle of litigation, delay, if unexplained, is fatal. 

The Court refused to condone a substantial delay of 600 days in filing the Special Leave Petition by the Revenue, holding that no satisfactory explanation was furnished.

This ruling underscores that even government authorities are not entitled to procedural leniency in the absence of reasonable cause. 

The Court’s refusal to even examine the merits highlights that limitation is not a technicality but a substantive safeguard ensuring certainty and finality in litigation. The decision serves as a sharp reminder that diligence in litigation timelines is non-negotiable.


The matter arose in Commissioner of Income Tax & Anr. v. M/s Mphasis Limited, Special Leave Petition (Civil) Diary No. 11444/2026, decided on 16.03.2026 b...

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