The Court further observed that the Special Leave Petition had been filed with an inordinate delay of 426 days. The explanation offered for the delay, attributing it to departmental and administrative procedures, was held to be vague and unacceptable. The High Court proceedings originated from a writ petition challenging a reassessment notice issued for Assessment Year 2014–15. The assessee filed objections to the reopening, which were rejected by the Assessing Officer. It was also submitted that the reopening was triggered by an audit objection without independent application of mind by the Assessing Officer.