https://www.taxtmi.com/caselaws?id=63800 Section 158BD requires the Assessing Officer to record an objective and cogent satisfaction, based on seized material or material relatable to it, that undisclosed income belongs to a person other than the searched person before initiating action against that other person. A mere reference to documents or an appraisal report is insufficient if the note does not expressly show the necessary jurisdictional satisfaction. On the stated facts, no enquiry or investigation was shown between the search and the notice, and the jurisdictional foundation was held invalid, resulting in annulment of the assessment made pursuant to that notice. en-us Tue, 16 Mar 2004 00:00:00 +0530 Wed, 02 Feb 2011 10:12:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=63800 Section 158BD requires the Assessing Officer to record an objective and cogent satisfaction, based on seized material or material relatable to it, that undisclosed income belongs to a person other than the searched person before initiating action against that other person. A mere reference to documents or an appraisal report is insufficient if the note does not expressly show the necessary jurisdictional satisfaction. On the stated facts, no enquiry or investigation was shown between the search and the notice, and the jurisdictional foundation was held invalid, resulting in annulment of the assessment made pursuant to that notice. Case-Laws Income Tax Tue, 16 Mar 2004 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=63800