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HC held that the Office note dated 29.8.2002 did not constitute a valid recording of "satisfaction" as required by s.158BD (read with s.158BC), because it merely reflected investigatory efforts and speculative material rather than an AO's reasoned satisfaction based on proximate, relevant evidence. Consequently, notices issued under s.158BD pursuant to a letter dated 5.8.2003 were held time-barred as not contemporaneous with the block assessment completed on 28.8.2002. The HC set aside the initiation of proceedings under s.158BD and allowed the assessee's cross-objection, concluding the departmental action was invalid for want of statutory satisfaction and for being barred by limitation.
HC held that the Office note dated 29.8.2002 did not constitute a valid recording of "satisfaction" as required by s.158BD (read with s.158BC), because it merely reflected investigatory efforts and speculative material rather than an AO's reasoned satisfaction based on proximate, relevant evidence. Consequently, notices issued under s.158BD pursuant to a letter dated 5.8.2003 were held time-barred as not contemporaneous with the block assessment completed on 28.8.2002. The HC set aside the initiation of proceedings under s.158BD and allowed the assessee's cross-objection, concluding the departmental action was invalid for want of statutory satisfaction and for being barred by limitation.
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