ACIT v. Marico Industries Ltd. (2025) 303 Taxman 405 (SC) Editorial: ACIT v. Marico Industries Ltd. (2025) 171 taxmann.com 140 (Bom.)(HC)

S. 158BC : Block assessment-Search and seizure-Authorisation-Penalty-Additional ground-Absence of satisfaction note-Invalid search-High Court order affirmed-Delay in SLP-SLP dismissed on delay and merits.[S. 132, 158BFA, Art. 136]

In block assessment proceedings, the assessee argued there was no valid satisfaction note for issuing a search warrant. Despite Tribunal directions, the revenue failed for years to produce it, later claiming it was destroyed in a fire. The High Court held that without the satisfaction note, the search and consequent assessment, penalty under section 158BFA, and criminal case could not survive. The Supreme Court dismissed revenue’s SLP due to delay of 404 days and on merits.

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