TaxTMI 
TaxTMI 
2016 (12) TMI 815
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....Agarwal, learned counsel for the department and Sri Shakeel Ahmad along with Sri Ashish Bansal for the assesee. This is a department's appeal filed under Section 260-A of the Income Tax Act, 1961 against an order dated 12.9.2008 passed by the Income Tax Appellate Tribunal for the block assessment period ending on 4th of June of 2002. The following questions of law have been sought to be answ....
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....n importing the time limit for initiating the proceedings u/s 158 BD although the statute make no such provision." The facts of the case are that a search was conducted on 04.06.2002 in the case of Sri Jaswant Singh and the block assessment, in his case, was framed on 18.06.2004. During the course of search, certain documents were seized which showed substantial undisclosed income in purchase of ....
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....orporation Vs. CIT (1998) 229 ISTR 383. The ITAT did not go into the merits and held that the proceedings initiated u/s 158 BD in the hands of the assessee were invalid on the grounds that:- (i) That no satisfaction was recorded by the AO having jurisdiction over the person searched. (ii) That such satisfaction had not been recorded on or before the completion of asstt. proceedings in the case....
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....ction 158BD of the Income Tax Act. On the contrary the tribunal has recorded categorical finding of fact that no satisfaction as is required to be recorded with regard to the re-opening of the case was done in the case of the present assessee in order to initiate proceedings under Section 158BD of the I.T. Act. Learned counsel for the department has sought to argue that the tribunal has, however....