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TMI Blog2010 (8) TMI 957X X X X Extracts X X X X X X X X Extracts X X X X ..... y the revenue under section 260A of the Income-tax Act, 1961 (in short "the Act") against the order of the Income-tax Appellate Tribunal, Chandigarh Bench (B), Chandigarh (hereinafter referred to as "the Tribunal") passed in IT (SS) A. No. 19/Chd./2009, dated 27-8-2009 for the block period 1-4-1996 to 5-2-2003, proposing to raise the following substantial question of law:- &qu ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... atisfaction on 31-3-2006. Notice under section 158BD was issued on 2-12-2006 which was contested by the respondent on the ground that the satisfaction note itself was after conclusion of the proceedings and not during the course of assessment proceedings. This plea was upheld by the CIT(A) following earlier judgment of the Tribunal in Manoj Aggarwal v. Dy. CIT [2008] 113 ITD 377 (Delhi)(SB). The T ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Act in the case of the person searched. It would, thus, mean that the action contemplated under section 158BD of the Act against a third party to a search, is necessarily to be during the course of block assessment proceedings under section 158BC of the searched person. It cannot be after the conclusion of the same as there is no occasion for an Assessing Officer to examine the seized material or ..... X X X X Extracts X X X X X X X X Extracts X X X X
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