https://www.taxtmi.com/caselaws?id=449601 The Calcutta HC set aside a block assessment order under Section 158BC(c) due to procedural violations. The court held that under Section 158BD, the Assessing Officer must record a satisfaction note based on cogent material before initiating proceedings when seized documents belong to someone other than the searched person. Since the AO failed to prepare the mandatory satisfaction note either before, during, or after assessment proceedings, the entire process was deemed patently illegal. Despite sufficient evidence including seized books, statements under Section 131, and explanatory letters being available on record, the absence of the required satisfaction note rendered the assessment invalid. The appeal was decided in favor of the assessee. en-us Tue, 06 Feb 2024 00:00:00 +0530 Thu, 29 Aug 2024 11:37:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=449601 The Calcutta HC set aside a block assessment order under Section 158BC(c) due to procedural violations. The court held that under Section 158BD, the Assessing Officer must record a satisfaction note based on cogent material before initiating proceedings when seized documents belong to someone other than the searched person. Since the AO failed to prepare the mandatory satisfaction note either before, during, or after assessment proceedings, the entire process was deemed patently illegal. Despite sufficient evidence including seized books, statements under Section 131, and explanatory letters being available on record, the absence of the required satisfaction note rendered the assessment invalid. The appeal was decided in favor of the assessee. Case-Laws Income Tax Tue, 06 Feb 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=449601