TMI Blog2019 (2) TMI 1333X X X X Extracts X X X X X X X X Extracts X X X X ..... bjections in respect of the same and requested the respondent to pass a reasoned order disposing of the same. However, the respondent instead of deciding the objections, has straightaway proceeded to pass assessment order under section 143(3) read with section 153C read with section 153A(1)(b) of the Income Tax Act, 1961. Having regard to the submissions advanced by the learned advocate for the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 3.2018, i.e. after a period of more than one year from the date of the assessment order. 2. Reference was made to the decision of the Supreme Court in case of Commissioner of Income Tax-III v. Calcutta Knitwears, 362 ITR 673 wherein, the Court has held that for the purpose of section 158BD a satisfaction note is sine qua non and must be prepared by the Assessing Officer before he transmits th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e Court in Calcutta Knitwears s case (supra) apply to proceedings under section 153C of the Act for the purposes of assessment of income of the person other than the searched person. It was submitted that in this case there is an inordinate delay from the date when the assessment proceedings have been completed under section 153A of the Act of the searched person, and therefore, the initiation of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... issued notice under section 153C of the Act for six years, i.e. from Assessment Year 2009-10 to Assessment Year 2014-15. It was submitted that the fact that such notices have been issued even for Assessment Year 2009-10 to Assessment Year 2012- 13 shows non-application of mind to the provisions of the first proviso to section 153C of the Act. 4. Lastly, it was submitted that in this case the se ..... X X X X Extracts X X X X X X X X Extracts X X X X
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