https://www.taxtmi.com/caselaws?id=445916 For invoking section 158BD of the Income-tax Act, the Assessing Officer of the searched person must first record a satisfaction note that undisclosed income belongs to a person other than the searched person and then transmit the material to the jurisdictional Assessing Officer. That recording is a jurisdictional precondition, not a mere procedural formality, and its absence invalidates initiation of proceedings. The Revenue's failure to produce the original files despite opportunity supported an adverse inference that no satisfaction note had been recorded. The court therefore held that assumption of jurisdiction under section 158BD was bad in law and the issue was answered in favour of the assessee. en-us Tue, 31 Oct 2023 00:00:00 +0530 Wed, 22 Nov 2023 08:12:21 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=445916 For invoking section 158BD of the Income-tax Act, the Assessing Officer of the searched person must first record a satisfaction note that undisclosed income belongs to a person other than the searched person and then transmit the material to the jurisdictional Assessing Officer. That recording is a jurisdictional precondition, not a mere procedural formality, and its absence invalidates initiation of proceedings. The Revenue's failure to produce the original files despite opportunity supported an adverse inference that no satisfaction note had been recorded. The court therefore held that assumption of jurisdiction under section 158BD was bad in law and the issue was answered in favour of the assessee. Case-Laws Income Tax Tue, 31 Oct 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=445916