2020 (2) TMI 268

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..... by Mr.K.G.Usha Rani Standing Counsel for IT Department For the Respondent : Mr.Venkat Narayanan For Subharaya Aiyar Padmanaban COMMON JUDGMENT DR.VINEET KOTHARI, J. The learned counsel for the Appellant/Revenue submitted that the Tribunal had quashed the block assessments for the Assessee for the following observations: ".... In this case, un-disputably there is no satisfact....

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....we set aside the order of Assessing Officer and cancel the block assessment in the case of the assessee." 2.He however submitted that the CBDT had recently issued a Circular No.24/2015 dated 31.12.2015, according to which, where satisfaction is not recorded by the competent authority then appeals against such orders of Tribunal granting relief to the Assessee has to be withdrawn by the Revenue ....

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....repared at any of the following stages: a) at the time of or along with the initiation of proceedings against the searched person under section 158BC of the Act: or (b) in the course of the assessment proceedings under section 158BC of the Act; or (c) immediately after the assessment proceedings are completed under section 158BC of the Act of the searched person." ....

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....f the above, filing of appeals on the issue of recording of satisfaction note should also be decided in the light of the above judgement. Accordingly, the Board hereby directs that pending litigation with regard to recording of satisfaction note under section 158BD /l53C should be withdrawn/not pressed if it does not meet the guidelines laid down by the Apex Court. F.No.279/Misc./140 /2015/ITJ ....