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2015 (1) TMI 748 - HC - Income TaxAssessment proceedings under Section 158BC - Satisfaction note non accord with the requirements of Section 158 BD - Held that:- Since the limitation period for completion of block assessment, or in the case of searched persons as well as the third party who is issued notice is two years, it is reasonable to assume that the revenue can be given latitude of six months which can be considered as “immediate” or immediately proximate in point of time. In the present case, the six month period expired on 28.02.2003; the satisfaction note was recorded on 06.03.2003 and the notice was issued more than 3 ˝ months after lapse of the date i.e. 18.06.2003. In these circumstances this Court holds that the notices did not accord with the Supreme Court’s declaration of law in MANISH MAHESHWARI case [2007 (2) TMI 148 - SUPREME COURT OF INDIA] and was unduly delayed. They cannot be considered as having been recorded immediately after the completion of assessment proceedings under Section 158BC Income Tax Act. - Decided in favour of assessee.
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