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2010 (7) TMI 718 - PUNJAB AND HARYANA HIGH COURTBlock assessment - recording of satisfaction under section 158BD - completion of assessment under section 158BC - period of limitation - held that:- It is not disputed that the premises of the S. K. Bhatia and group were searched on February 5, 2003, and block assessment under section 158BC was framed on March 30, 2005. The satisfaction as contemplated under section 158BD in the case of the assessee was recorded on July 15, 2005, as observed by the Assessing Officer of the person searched, i.e., the Assistant Commissioner of Income-tax, Central Circle-II, Ludhiana, and notice was issued on February 10, 2006. Since the block assessment in the case of the S. K. Bhatia group under section 158BC of the Act was framed on March 30, 2005, whereas the satisfaction as contemplated under section 158BD in the case of the present assessee was recorded on July 15, 2005, thus, the proceedings were bad in law. - Decided against the revenue.
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