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Recording of satisfaction note under section 158BD/153C of the Act

Income Tax - 24/2015 - Dated:- 31-12-2015 - CIRCULAR NO. 24/2015 F.No.279/Misc./140/2015/ITJ Government of India Ministry of Finance Department of Revenue Central Board of Direct Taxes New Delhi, 31st December, 2015 Subject: - reg. The issue of recording of satisfaction for the purposes of section 158BD/I53C has been subject matter of litigation. 2. The Hon'ble Supreme Court in the case of M/s Calcutta Knitwears in its detailed judgment in Civil Appeal No.3958 of 2014 dated 12.3.2014(availab .....

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n under section 158BC of the Act; or (b) in the course of 'the assessment proceedings under section 158BC of the Act; or (c) immediately after the assessment proceedings are completed under section 158BC of the Act of the searched person. " 3. Several high Courts have held that the provisions of section 153C of the Act are substantially similar/pari-materia to the provisions of section 158BD of the Act and therefore, the above guidelines of the Hon'ble SC, apply to proceedings u/s 1 .....

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