Assessment Quashed Due to 9-Month Delay in Recording Satisfaction Under Section 158BD

PCIT Vs Jitendra H Modi Huf (Gujarat High Court) Summary: The Revenue filed an appeal before the High Court challenging the order of the Income Tax Appellate Tribunal dated 16 March 2017. The primary issue concerned the validity of proceedings initiated under Section 158BD of the Income-tax Act and whether the Tribunal was justified in quashing the assessment on account of delay in recording satisfaction. A second issue related to deletion of addition of ₹36.67 lakh treated as undisclosed income for the block period from Assessment Year 1992–93 to 2001–02. The case arose from a search a...