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2015 (2) TMI 293 - HC - Income TaxProcedure for block assessment - proceedings under sections 158BC and 158BD - reasonable period of time in issuing notice - Held that:- In light of the position of law declared in Commissioner of Income Tax v. V.K. Narang HUF, [2015 (1) TMI 566 - DELHI HIGH COURT] this Court finds that the delay of 5 months in the issuing of notice by the A.O. in the present appeals cannot be unreasonable. Accordingly, the impugned orders of the ITAT is set aside on this aspect. The satisfaction note is held to be validly issued and within a reasonable time. In the light of the above observations of the Supreme Court in Calcutta Knitwears [2014 (4) TMI 33 - SUPREME COURT], particularly the contextual facts discussed (i.e. completion of the searched party’s assessment on 31-03-2005, satisfaction note under Section 158BD issued on 15-07-2005 and notice issued on 10-02-2006) it cannot be said that the delay in issuing the notice (although the satisfaction note was recorded within reasonable time) was fatal to the block assessment against the present assesse. Decided against assessee.
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