Section 158B – Initiation of Block Assessment without Valid satisfaction is invalid

Brief Facts of the case:

A search was conducted in the premises of Mr Manoj Agarwal on 03-08-2000 and documents were seized.The present assesses were issued a notice on 22.03.2004 alleging that the same has been issued on account of opinion formation in terms of sec 158BB of Manoj Aggarwal’s assessing Officer. The opinion was read as under:

“1) Various diaries have been seized from the possession of Sh. Manoj Aggarwal which establish that

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