https://www.taxtmi.com/caselaws?id=245534 The SC held that before initiating proceedings under Section 158BD for assessment of undisclosed income belonging to persons other than the searched person, the assessing officer must record satisfaction in writing. This satisfaction note is sine qua non and must be prepared before transmitting records to the jurisdictional assessing officer. The Court distinguished this from Section 148 provisions, emphasizing that cogent and demonstrative material is necessary to conclude that seized documents belong to another person. Since the assessing officer failed to record the required satisfaction note, the Tribunal and HC were justified in setting aside the assessment orders. The matter was remitted back to the HC for consideration. Decision against Revenue. en-us Wed, 12 Mar 2014 00:00:00 +0530 Thu, 19 Jun 2025 18:13:52 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=245534 The SC held that before initiating proceedings under Section 158BD for assessment of undisclosed income belonging to persons other than the searched person, the assessing officer must record satisfaction in writing. This satisfaction note is sine qua non and must be prepared before transmitting records to the jurisdictional assessing officer. The Court distinguished this from Section 148 provisions, emphasizing that cogent and demonstrative material is necessary to conclude that seized documents belong to another person. Since the assessing officer failed to record the required satisfaction note, the Tribunal and HC were justified in setting aside the assessment orders. The matter was remitted back to the HC for consideration. Decision against Revenue. Case-Laws Income Tax Wed, 12 Mar 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=245534