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2014 (9) TMI 15 - HC - Income TaxUndisclosed income u/s 158BD r.w. section 158BC - Whether the Tribunal was right in holding that additions deleted could not have been made as they do not represent the undisclosed income for the purpose of Section 158BD r.w. Section 158BC – Held that:- The assessee during the course of appellate proceedings before the Tribunal had not challenged satisfaction or rather had given up challenge to validity of proceedings u/s 158BD of the Act - whether or not the AO had rightly and validly initiated proceedings u/s 158BD would depend upon whether the AO of the person searched had recorded his satisfaction - It is nowhere stated or indicated that the assessee would be entitled to challenge initiation or validity of proceedings u/s 158BD of the Act - the block assessment proceedings were initiated by issue of notice u/s 158BD on 31st May, 1996 - after a lapse and delay of 16 years, it would not be possible for the Revenue to locate complete records, papers and file notings therein - There must have been a good and strong reason for the same – Decided in favour of revenue.
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