For the purpose of Section 158BD a satisfaction note is sine qua non -SC

CA Sandeep Kanoi Honourable SC has held in the case of CIT vs. Calcutta Knitwears that for the purpose of Section 158BD of the Act a satisfaction note is sine qua  non and must be prepared by the assessing officer before he transmits the records to the other assessing  officer who has jurisdiction over such other person. The satisfaction note could be prepared at either of the following stages: (a) at the time of or along with the initiation of proceedings against the searched  person under Section 1 58BC of the Act; (b) along with the assessment proceedings under Section 158BC  of the ...