Case Law Details
Pr. CIT Vs. Instronics Ltd. (Delhi High Court)
In the present case, the ITAT overlooked the fact that the Satisfaction Note was in fact recorded by the assessing officer of the searched person who also happened to be the assessing officer for the assessee (the other person) as well. This is clear from the sentence in the Satisfaction Note which reads : “The undersigned is the jurisdictional assessing officer of these cases.” The assessing officer of the searched person has recorded the satisfaction that the seized documents belonged to the assessee. In similar circumstances in Satkar Fincap Ltd. (supra), this Court held likewise. The Satisfaction Note in the present case, therefore, satisfies the requirement of the law. Consequently, the question framed is answered in the negative i.e., in favour of the Revenue and against the assessee.
Full Text of the High Court Judgment / Order is as follows:-
For the reasons explained in the applications, the delay in filing as well as re-filing is condoned. The applications are disposed of.
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