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2012 (6) TMI 630 - AT - Income TaxBlock assessment – search – undisclosed income - assessment orders under section 158BC were passed in these cases on 6-7-2007 - satisfaction note/letter was written on 13.7.2007 - Revenue has placed no material on record to show any undisclosed income – Held that:- in the case of Mukta Metal Works (2011 (2) TMI 250 (HC)) was held that according to the provisions of section 158BD of the Act the satisfaction has to be recorded between the initiation of the proceedings u/s 158BC and before completion of block assessment u/s 158BC of the Act in the case of person searched. It could not be after the conclusion of the block assessment as there was no occasion for an AO to examine the seized material or documents of the person searched when the block assessment proceedings had concluded and no other proceedings were pending before him. order passed was contrary to the provisions of section 158BD of the Act and needs to be quashed. Decided in favor of assessee.
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