2011 (2) TMI 758

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....x Appellate Tribunal, Delhi Bench 'G', Delhi in I.T.A. No.95/Del/2008 for the block assessment period 1.4.1990 to 3.8.2000 raising following substantial questions of law:-   "i) Whether on the facts and in the circumstance of the case, the ld. ITAT was right in law in holding that the notice u/s 158BD issued on 23.9.2004 is beyond reasonable time from the date of completion of the block assessment in the case of searched persons, therefore, on the limitation ground, the proceedings initiated u/s 158BD are invalid and are thus, liable to be cancelled even though there is no time limit prescribed for issuing notice u/s158 as per section 158BD read with section 158BC of the Income Tax Act, 1961?   ii) Without prejudice to the q....

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....ons who have taken accommodation entries and to protect the interest of revenue, he added the same to the income of the company i.e. and Friends Portfolio (P) Ltd., on protective basis?"   3. Block assessment proceedings were initiated against the assessee on account of material found during the search on the residential and office premises of Manoj Aggarwal and his associates M/s Friends Portfolio P Ltd. on 3.8.2000. During the assessment of the searched person which was completed on 29.8.2002, it was noticed that Manoj Aggarwal was engaged in giving bogus accommodation book entries and the persons to whom such entries were given included the assessee. On requisite satisfaction having been formed, the concerned assessing officer wa....