https://www.taxtmi.com/caselaws?id=247231 The HC held that under Section 158BD, the assessing officer must record a satisfaction note before issuing a notice to another person regarding undisclosed income. The AO failed to record such satisfaction before issuing the notice under Section 153C. Both the CIT(A) and ITAT correctly found no evidence of the required satisfaction note. The court affirmed that the provisions of Sections 158BD and 153C are pari materia, and without the satisfaction note, the notice issuance was invalid. The appeal under Section 260-A was dismissed, and the decision was against the Revenue. en-us Thu, 01 May 2014 00:00:00 +0530 Thu, 31 Jul 2025 15:38:50 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=247231 The HC held that under Section 158BD, the assessing officer must record a satisfaction note before issuing a notice to another person regarding undisclosed income. The AO failed to record such satisfaction before issuing the notice under Section 153C. Both the CIT(A) and ITAT correctly found no evidence of the required satisfaction note. The court affirmed that the provisions of Sections 158BD and 153C are pari materia, and without the satisfaction note, the notice issuance was invalid. The appeal under Section 260-A was dismissed, and the decision was against the Revenue. Case-Laws Income Tax Thu, 01 May 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=247231