Block Assessment Under Section 158BD Quashed Due to Defective Satisfaction Note Despite Timely Recording

The ITAT allowed the assessee's appeal, setting aside the block assessment order due to improper assumption of jurisdiction under section 158BD. The Tribunal found that although the satisfaction was recorded within a reasonable timeframe after completion of the searched person's assessment (within 1 month and 10 days), the AO failed to demonstrate proper mental application in the satisfaction note. The satisfaction merely contained casual references to seized documents without revealing the requisite dispassionate thought process. Consequently, the notice issued under section 158BC read with 158BD and the subsequent assessment order were held legally unsustainable due to the jurisdictional defect in the satisfaction recorded by the AO. .....

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