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    <title>2025 (3) TMI 644 - ITAT CHANDIGARH</title>
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    <description>The ITAT Chandigarh set aside the block assessment order passed by the AO under section 158BD. The tribunal found that the AO&#039;s assumption of jurisdiction was vitiated due to inadequate satisfaction recorded before initiating proceedings under section 158BD. While the AO had recorded satisfaction on 10/09/1996 and issued notice on 13/09/1996, the satisfaction lacked proper reasoning and was based merely on casual reference to seized documents. The tribunal held that the satisfaction must contain dispassionate thought process and reasons for initiating proceedings, which was absent in this case. The appeal was allowed and the assessment order dated 28/10/1996 was set aside.</description>
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    <pubDate>Thu, 06 Feb 2025 00:00:00 +0530</pubDate>
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      <title>2025 (3) TMI 644 - ITAT CHANDIGARH</title>
      <link>https://www.taxtmi.com/caselaws?id=767258</link>
      <description>The ITAT Chandigarh set aside the block assessment order passed by the AO under section 158BD. The tribunal found that the AO&#039;s assumption of jurisdiction was vitiated due to inadequate satisfaction recorded before initiating proceedings under section 158BD. While the AO had recorded satisfaction on 10/09/1996 and issued notice on 13/09/1996, the satisfaction lacked proper reasoning and was based merely on casual reference to seized documents. The tribunal held that the satisfaction must contain dispassionate thought process and reasons for initiating proceedings, which was absent in this case. The appeal was allowed and the assessment order dated 28/10/1996 was set aside.</description>
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      <pubDate>Thu, 06 Feb 2025 00:00:00 +0530</pubDate>
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