https://www.taxtmi.com/caselaws?id=14043 A notice for block assessment against a non-raided person under s.158BD was challenged as void for want of the raiding party's AO's "satisfaction" and non-application of mind. HC held that, absent any pleading specifically alleging lack of such satisfaction and without impleading the raidees' AO, no adverse inference could be drawn from the respondent AO's affidavit. Since seized books/documents were admittedly handed over, the Court invoked the presumption under s.114 Evidence Act that official acts were regularly performed, and rejected the claim that the Court must independently verify satisfaction as a jurisdictional fact in the abstract. The notice was upheld and the writ petition was dismissed with costs. en-us Wed, 24 Jan 2001 00:00:00 +0530 Wed, 07 Jan 2026 15:26:03 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=14043 A notice for block assessment against a non-raided person under s.158BD was challenged as void for want of the raiding party's AO's "satisfaction" and non-application of mind. HC held that, absent any pleading specifically alleging lack of such satisfaction and without impleading the raidees' AO, no adverse inference could be drawn from the respondent AO's affidavit. Since seized books/documents were admittedly handed over, the Court invoked the presumption under s.114 Evidence Act that official acts were regularly performed, and rejected the claim that the Court must independently verify satisfaction as a jurisdictional fact in the abstract. The notice was upheld and the writ petition was dismissed with costs. Case-Laws Income Tax Wed, 24 Jan 2001 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=14043