Garden City Education Trust v. Dy. CIT (E) (2024) 300 Taxman 594 (SC) Editorial : Garden City Education Trust v. Dy. CIT (E) (2024) 165 taxmann.com 463 (Karn)(HC), affirmed.

S. 260A : Appeal-High Court-Review petition before High Court which was dismissed as withdrawn without any liberty-SLP against order of High Court which was also dismissed-Another Review petition is also dismissed-SLP is dismissed. [Art. 136]

Review petition before High Court which was dismissed as withdrawn without any liberty. SLP against order of High Court which was also dismissed. Assessee filed another review petition which was also dismissed. Assessee filed  special leave petition.  Since assessee did not seek liberty to file second review petition at initial stage or before Supreme Court, non-seeking of liberty was fatal to case of assessee. Filing of initial Review Petition and thereafter withdrawing same and pursuing Special Leave Petition and on its dismissal once again filing another Review Petition was not in accordance with policy of attaining finality in litigation. After dismissal of special leave petition by Supreme Court, assessee could not have filed another review petition before High Court as there must be an end to litigation otherwise rights of persons would be in an endless confusion and justice would suffer and, thus, SLP is  dismissed. (AY. 1995-96 to 1998-99)

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