CIT v. Jitendra H. Modi HUF (2018) 403 ITR 110 (Guj) (HC)

S. 158BD : Block assessment – Undisclosed income of any other person -Recording of satisfaction can be done even after assessment of person searched , however must be recorded with in reasonable time. Recording of satisfaction was done after nine months after assessment of person searched is held to be bad in law. [ S.158BC ]

Dismissing the appeal of the revenue the Court held that , recording of satisfaction can be done even after assessment of person searched , however must be recorded with in reasonable time . On facts recording of satisfaction was done after nine months after assessment of person searched is held to be bad in law. (CIT v. Calcutta Knitwears (2014) 362 ITR 673 (SC)) [B P 1992-93 to 2001-02 ]