Delay in issuing notice u/s 158BD by 10 months cannot be considered contemporaneous

Brief Facts of the case- ♣ It is a case of appeals involving common questions of law, accordingly a common order had been made in these cases. ♣ In all these cases, assessee/respondents were third parties, who were issued notice under Section 158BD pursuant to search proceedings in respect of other persons. In all these cases, the search proceedings were conducted on 03.08.2000. The assessment proceedings were completed on 29.08.2002. Thereafter, the present assesses-third parties were issued notices under Section 158BD. ♣ These appeals were originally disposed of by common judgment of t...