PCIT v. Milia Tracon (P.) Ltd (2024) 165 taxmann.com 150 (2025) 473 ITR 155 (Cal)(HC)

S. 158BD : Block assessment-Undisclosed income of any other person-Search and Seizure-Recording of satisfaction-Failure to follow the mandatory procedure-Order is bad in law.[S. 132, 158BC, 260A]

Dismissing the appeal of the Revenue the Court held that since Assessing Officer of searched person had not recorded any satisfaction note for initiating proceedings under section 158BD against assessee and also had not handed over to Assessing Officer of assessee seized documents, etc., to enable him to proceed under section 158BC, the order passed by Assessing Officer is  without jurisdiction and unauthorized. (AY.1996-2002)

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