https://www.taxtmi.com/caselaws?id=243924 The Court upheld the decision that the notice issued under Section 158BD to the assessee, a third party, was invalid due to being issued beyond the prescribed time limit. It emphasized that the satisfaction for issuing the notice should have been recorded during the searched person's assessment proceedings. The Court rejected the argument that the limitation period for third-party assessments starts from notice issuance, emphasizing alignment with the searched person's proceedings. It clarified that the Assessing Officer must base jurisdiction on materials from the searched person's assessment to prevent arbitrary actions. The Court affirmed the importance of adhering to procedural requirements to avoid abuse of discretion and dismissed the appeal. en-us Thu, 06 Feb 2014 00:00:00 +0530 Sat, 05 Apr 2014 09:59:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=243924 The Court upheld the decision that the notice issued under Section 158BD to the assessee, a third party, was invalid due to being issued beyond the prescribed time limit. It emphasized that the satisfaction for issuing the notice should have been recorded during the searched person's assessment proceedings. The Court rejected the argument that the limitation period for third-party assessments starts from notice issuance, emphasizing alignment with the searched person's proceedings. It clarified that the Assessing Officer must base jurisdiction on materials from the searched person's assessment to prevent arbitrary actions. The Court affirmed the importance of adhering to procedural requirements to avoid abuse of discretion and dismissed the appeal. Case-Laws Income Tax Thu, 06 Feb 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=243924