Where in the course of search, material is found pertaining to any other person, then in terms of section 158BD, the right course of action is to hand over the seized material to the AO of the said person, who would then proceed to carry out the assessment as per section 158BC of the Act. Appeal of revenue is dismissed . Question no (b) followed CIT v. HDFC Bank Ltd ( 2014 )366 ITR 505 (Bom) (HC) . As regards depreciation on lease back question is admitted and will be heard along with ITA No 927 of 2014 . (AY. 1996-97 to 1998-99)
PCIT v. HDFC Bank Ltd. (2019) 174 DTR 92 (Bom.)(HC)
S. 158BD : Block assessment – Undisclosed income of any other person – To hand over the seized material to the AO of the said person to proceed u/s. 158BC-No substantial question of law .. [S. 158BC, 260A]