Valid “Satisfaction Note” as required u/s 158BD requires proper recording of evidences for being satisfied

Brief Facts of the case- ♠ The subject appeals are filed on similar grounds and accordingly have been discharged by a single order. ♠ The present appeal has been received on limited remit by the Hon’ble Supreme Court which had by its judgment reported as CIT V. Calcutta Knitwear (2014) 362 ITR 673 (SC) directed examination of the limited question as to whether opinion formation, in terms of Section 158BB of the Income Tax Act, and the time within which it had to be recorded was complied with. ♠ A search was conducted on 3.8.2000 in the premises of Sh. Manoj Aggarwal. This led to the se...