2019 (11) TMI 875

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.... SRI. Y.V. RAVIRAJ, ADVOCATE) RESPONDENT (BY SRI. SANGRAM S. KULKARNI, ADVOCATE) JUDGMENT ALOK ARADHE, J, Sri. Y. V. Raviraj learned counsel for the Revenue. 2. Sri. Sangram S Kulkarni, learned counsel for the respondent. 3. Heard on the question of admission. 4. This is an appeal under Section 260A of the Income Tax Act, 1961, (hereinafter referred to as "Act" for short) agai....

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....bunal by filing an appeal, which has been dismissed by the impugned order dated 07.12.2017. By way of cross-objection, the Assessee raised issue with regard to non-recording of satisfaction before invoking provision of Section 153C of the Act. In the aforesaid factual background, this appeal has been filed. 6. Learned counsel for the Revenue, while inviting the attention of this Court to the no....

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.... the submissions made by the learned counsel for the parties and have perused the records. 9. The Ministry of Finance, Government of India has issued a circular namely Circular No.24/2015, which deals with recording of satisfaction note under Section 158BD/153C of the Act. In view of the decision of the Hon'ble Supreme Court in the case of M/s.Calcutta Knitwears (supra) it has been held that th....

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....O shall proceed against such other person in the same manner as the person searched to make the assessment or reassessment in accordance with the provisions of Section 153A. 10. We have carefully gone through the satisfaction note recorded by the Assessing Officer dated 06th of January, 2014. The aforesaid assessment note nowhere satisfies the requirements referred to, in the preceding paragrap....