No delay in issuance of notice u/s 158BD if AO records satisfaction in time

Issue before Court: Whether ITAT was right in dismissing appeal of revenue on ground of delay in issuance of notice u/s 158BD. Brief facts: On 03.08.2000 a search was conducted under Section 132 of the Act at the business premises of M/s Friends Portfolio Pvt. Ltd. and at the residential premises of its Director, Shri Manoj Aggarwal. During the search and the course of investigation and assessment proceedings DCIT found that that Sh. Manoj Aggarwal provided bogus accommodation entries to various individuals. The beneficiaries included the present respondent-assessees who received accommodatio...