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2010 (7) TMI 664 - HC - Income TaxSearch and seizure - Block assessment - Undisclosed income - Time barred - The plain and reasonable construction that can be placed on the aforesaid provision would be that the recording of satisfaction for taking action against any other person under section 158BD of the Act has to be between initiation of proceedings under section 158BC and before completion of block assessment under section 158BC of the Act in the case of the person searched - It could not be read in the provision that where block assessment under section 158BC of the Act in the case of an assessee against whom action under section 132 or 132A of the Act had been carried out is finalized, the Revenue can take action at any time in the absence of any specific limitation prescribed in the statute - The satisfaction having been recorded and the proceedings initiated after finalization of the block assessment in the case of S. K. Bhatia's group on March 30, 2005, the same were bad in law - Decided in favour of the assessee
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