2015 (1) TMI 748

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....ag Jain, Advs. ORDER Mr. Justice S. Ravindra Bhat (Open Court) 1. The present appeals have to be decided pursuant to a remittal and directions of the Supreme Court in its judgment reported as CIT vs. Calcutta Knitwears, Ludhina 362 ITR 673 (SC). The Court in its judgment had directed as follows: "44. In the result, we hold that for the purpose of Section 158BD of the Act a satisfaction note is....

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.... were justified in setting aside the orders of assessment and the orders passed by the first appellate authority. We do not intend to examine the aforesaid contention canvassed by the learned counsel since we are remanding the matters to the High Court for consideration of the individual cases herein in light of the observations made by us on the scope and possible interpretation of Section 158BD ....

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....ained, the Assessing Officer of the searched person recorded a satisfaction note on 06.03.2003 in the case of both assessees in the present appeals, taking the view that additional income had escaped assessment on the basis of this satisfaction note, which was forwarded to the Assessing Officer of the present assesses. The latter issued notice on 18.06.2003 to the respondent/assessee. After consid....

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....he notices were issued within the period mentioned in para 44 of Calcutta Knitwears (supra). It is evident from the narration of the facts discussed above that the satisfaction note was recorded more than six months after the assessment of searched person; the assessment was completed on 29.08.2002 and the satisfaction note was recorded 06.03.2003. This Court recollects that the extended period wi....