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| The Tax Publishers2020 TaxPub(DT) 1635 (Karn-HC) : (2020) 422 ITR 0284 : (2020) 316 CTR 0204 : (2020) 273 TAXMAN 0075 INCOME TAX ACT, 1961
section 158BD
Since satisfaction note implied that the same was recorded in respect of assessee and profit on undisclosed income from unused empty bottles was worked out, therefore, requirement as laid down by decision of the Supreme Court in case of Calcutta Knitwears as well as Circular dated 31.12.2015 issued by CBDT was complied with and assessment passed under section 158BD was valid.
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Search and seizure - Assessment under section 158BD - Absence of valid satisfaction recorded by AO on materials gathered in course of search of partner of assessee-firm -
Assessee challenged validity of assessment passed under section 158BD read with section 143(3) contending that there was absence of valid satisfaction recorded by AO after application of his mind on the materials gathered in the course of search of partner of the assessee-firm. Held: Perusal of satisfaction note implied that the same was recorded in respect of assessee and profit on undisclosed income from unused empty bottles was worked out. Therefore, requirement as laid down by decision of the Supreme Court in case of Calcutta Knitwears as well as Circular dated 31-12-2015 issued by CBDT was complied with.
Followed:CIT v. Calcutta Knitwears (2014) 362 ITR 673 (SC) : 2014 TaxPub(DT) 1547 (SC)
REFERRED :
FAVOUR : Against the assessee.
A.Y. :
INCOME TAX ACT, 1961
Section 143(3)
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