TMI Blog2020 (2) TMI 268X X X X Extracts X X X X X X X X Extracts X X X X ..... , according to which, where satisfaction is not recorded by the competent authority then appeals against such orders of Tribunal granting relief to the Assessee has to be withdrawn by the Revenue Department. In view of the aforesaid Circular, Mr.T.R.Senthil Kumar does not want to press the appeals on merits and seeks leave of this Court to withdraw the same. Mr.Venkat Narayanan, learned counsel ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... .158BD. We have also perused the block assessment passed under sec.158BC in the case of Veeraswamy Chettiar and found that the Assessing Officer has not even recorded any material found during the search showing the undisclosed income of the assessee. Therefore, in the absence of mandatory requirement of recording of satisfaction and moreover there was no material found during the search, t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... below for ready reference: RECORDING OF SATISFACTION NOTE UNDER SECTION 158BD/153C OF THE ACT. The issue of recording of satisfaction for the purposes of section I58BD/153C 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 = 2014-TIOL-30-SC-IT has laid ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 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 153C of the lT Act, for the purposes of assessment of income of other than the searched person. This view has been accepted by CBDT. 4. The guidelines of the Hon ble Supreme Court as referred to in para 2 above, with regard ..... X X X X Extracts X X X X X X X X Extracts X X X X
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