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2015 (1) TMI 566 - DELHI HIGH COURTInordinate delay in issuing the notice u/s 158BD to the assessee - Held that:- In the facts and circumstances of the present case, it cannot be held that there was any delay in recording the satisfaction note. The assessment of the searched person was completed on 31.12.2001. The satisfaction note was recorded on 30.05.2002 i.e. just about five months after the date of completion of searched person. Notice was issued on 03.06.2002, immediately after the satisfaction note was recorded to the present assessee. Thus there was no delay in issuance of notice under Section 158BD in the facts of the case. So far as the merits of the appeal are concerned, Court notices that the ITAT had not dealt with the merits of the assessee’s contentions with regard to the various additions made, and grounds urged in that regard. In these circumstances, the matter is remitted to the ITAT to decide the contentions on merits. - Decided partly in favour of assessee.
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