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Commissioner Of Income Tax Vs. Sudhir Dhingra
February, 09th 2015
                                           RESERVED ON: 07.01.2015
%                                       PRONOUNCED ON: 30.01.2015

+                        ITA 287/2009

       COMMISSIONER OF INCOME TAX                   ..... Appellant
                   Through: Mr. Rohit Madan, Sr. Standing Counsel
                   with Ruchir Bhatia, Advocates.

       SUDHIR DHINGRA                                  ..... Respondent
                       Through: Mr. Salil Aggarwal with Mr. Ravi
                       Pratap, Advocates.

                         ITA 1329/2009

       COMMISSIONER OF INCOME TAX                     ..... Appellant
                   Through: Mr. N.P. Sahni, Sr. Standing Counsel
                   with Mr. Nitin Gulati and Mr. Judy James, Jr.
                   Standing Counsel.

       RENU VERMA                                       ..... Respondent
                         Through: Mr. Vikas Jain, Advocate.

     1. These appeals under Section 260A of the Income Tax Act, 1961
       (hereafter "the Act") impugn an order dated 04.04.2008 of the
       Income Tax Appellate Tribunal (hereafter "the ITAT") in case of the

ITA 287 & 1329/2009                                                  Page 1
       respondent/assesses No.1 [in IT(SS)A No. 216/Del/2006 and CO.
       No.408/Del/2007 for the block period from 01.04.1990 to
       20.08.2000] & the order dated 17.04.2009 of the ITAT in case of the
       respondent/assessee No. 2, [in IT(SS)A No. 84/Del/2007 for block
       period 01.04.1990 to 03.08.2000]. The question of law urged before
       this Court is whether the ITAT was correct in holding that a notice
       must be issued by the Assessing Officer ("the A.O" in short) within
       a reasonable period of time in relation to assessment proceedings
       under sections 158BC and 158BD of the Act.
   2. The facts which give rise to the present appeal are that the
       Respondent/Assessees are individuals. 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 before the Deputy
       Commissioner of Income Tax (hereafter "the DCIT"), Central
       Circle-3, New Delhi, it was found that that Sh. Manoj Aggarwal
       provided bogus accommodation entries to various individuals. The
       beneficiaries included the present respondent-assessees who received
       accommodation entries in lieu of cash. The assessment u/s 158BC of
       M/s Friends Portfolio Ltd. was completed on 29.08.2002. The AO,
       after considering the materials, recorded to his satisfaction and
       issued a letter to the respective A.O.s of the respective assessees
       No. 1 & 2. Thereafter, the case of the assessees was taken up for
       scrutiny as per the provisions of section 158BD and statutory notices
       u/s 143(2) and 142(1) were issued and served upon them.
   3. The Relevant dates in the present appeals are as follows:-
       Assessee                Sudhir Dhingra          Renu Verma
       Present        Appeals IT(SS)      A      No. IT(SS)A             No.

ITA 287 & 1329/2009                                                     Page 2
       Arising from              216/Del/2006        84/Del/2007
       Date of Search of         03.08.2000          03.08.2000
       M/s Friends Portfolio
       Date of Completion        29.08.2002          29.08.2002
       of Assessment
       Recording            of   13.02.2003          13.02.2003
       Satisfaction by the
       A.O.       of       the
       Date of Issue of          10.07.2003          18.07.2003
       Notice by the A.O. of
       the relevant assessee
       Assessment Order          28.07.2005          31.08.2005
       Undisclosed Income        1,16,36,360/-       12,50,981/-
       of the Assessed (so
       Date of the Order of      07.07.2006          04.10.2006
       the CIT(A)
       Date of the Order of      04.04.2008          17.04.2009
       the ITAT

       On 10.07.2003 the A.O. of Assessee No. 1 issued a notice under
       Section 158BC read with Section 158BD of the Act to Assessee No.
       1 in the present appeal. On 21.08.2003 the assessee no. 1 filed a
       return declaring undisclosed income at "Nil" for the block period.
       Subsequently, after discussing the case with the Assessee no.1, the
       A.O. framed the block assessment at an undisclosed income of
       Rs.1,16,36,360/- after making additions on the account of
       unaccounted cash received/paid under the cover of bogus
       transactions of purchase/sale of shares. Aggrieved, assessee no. 1
       preferred appeal before the Commissioner of Income Tax (Appeals)
       (,,the CIT (A)) who by order dated 07/07/2006 deleted all the
       amounts brought to tax made by the AO. The revenue appealed this

ITA 287 & 1329/2009                                                  Page 3
       order of the CIT (As) order before the ITAT. Simultan eously the
       assessee no. 1 filed a cross objection urging the ground that the order
       passed by the A.O. was bad and liable to be quashed as the same was
       barred by limitation.
   5. Relevant portions of the orders of the Assessment Order, Order of
       the CIT(A) and the ITAT in the case of Assessee No. 1 have been
       reproduced as under:
   6. The AOs order dated 28.07.2005 inter alia, held that:
           "10. ....Assessed at total undisclosed income of Rs.
           1,16,36,360/- Charge tax @ 60% and interest u/s
           158BFA(1) of the Income Tax Act. As it is apparent from the
           order that the assessee was in possession of undisclosed
           income, which was deleted as a result of search & seizure
           proceedings, therefore, penalty proceedings u/s 158BFA(2)
           have been initiated, separately..."

   7. The relevant portion of the CIT (As) order is as follows:
           "....All these go to prove that not even an iota of evidence
           has been brought out on record to prove that the transaction
           of capital gain was bogus and that the amount of
           Rs.76,00,000/- and Rs.40,12,000/- for the purchase and sale
           of shares is hereby deleted. Similarly the addition of
           24,360/- made by the AO on surmises, treating the payment
           of brokerage and service tax on purchase and sale of shares
           as unaccounted cash without bringing any evidence on
           record is also hereby deleted. As a result appeal is

   8. The ITAT considered the merits of the revenues appeal as well as
       the assessees cross-objections, i.e., CO No.408/Del/2007. The
       ground raised by the assessee in his cross objection was on the issue
       of the assessement proceeding being time barred. Apart from the
       satisfaction being recorded by the AO on 13-02-2000, it was urged
       in the cross objection that that the notice under section 158BD was

ITA 287 & 1329/2009                                                      Page 4
       issued by the assessees A.O. on 10.07.2003. The assessee argued
       that this notice was unsustainable because the satisfaction was
       recorded belatedly and that impugned notice under Section 158BD
       was illegal because the satisfaction recorded by the A.O. of M/s
       Friends Portfolio was on 13.2.2003, notice under Section 158BD
       was issued only on 10.07.2003. The ITAT held that the satisfaction
       was recorded belatedly and that the notice was consequently bad.
       The assessee had relied on the judgment of the Gujarat High Court in
       Khandubhai Vasanji Desai & Others v. DCIT 236 ITR 73, where it
       was reasoned that a period of 60 days may be considered reasonable
       for issue of notice from the date of satisfaction recorded by the A.O.
       of searched persons. The ITATs impugned order held that;

           "6. ...In the present case, the satisfaction was recorded by
           the Assessing Officer of M/s Friends Portfolio Pvt. Ltd. on
           13.02.2003 whereas notice under section 158BD was issued
           by the Assessing Officer of the present assessee after almost
           five months and hence following the tribunal judgment
           rendered in the case of Shri Radhey Mohan Bansal (supra),
           we hold that there was no effective notice to the assessee
           within a reasonable period and hence the assessment
           requires to be vacated. We order accordingly.
           7. In the result, cross objection of the assessee is allowed.
           8. In view of the fact that block assessment is vacated, the
           appeal of the revenue does not survive and the same is

       In light of the searches conducted of M/s Friends Portfolio Ltd. and
       the premises of Sh. Manoj Aggarwal and the recording of the
       satisfaction of the A.O. therein, proceedings u/s 158BD were
       initiated against Assessee no. 2 and notice for the same was issued
       on 18.07.2003. Assessee No. 2 aggrieved with the assessment order

ITA 287 & 1329/2009                                                     Page 5
       dated 31.08.2005, filed an appeal before the Ld. CIT (A) which by
       order dated 04.10.2006 dismissed the appeal. Aggrieved with the
       order the assessee appealed to the ITAT which by its impugned
       order dated 17.04.2009 set aside the CIT (As) order.
   10.Relevant portions of the Assessment Order, Order of the CIT(A) and
       the Order of the ITAT in the case of Assessee No. 2 has been
       reproduced as under;
   11.The Assessment Order dated 31.08.2005 inter alia, held that:
           "With the remarks made as above, the total undisclosed
           income for the block period is assessed at Rs. 15,28,570/-.
           Penalty under Sec. 158BFA is being initiated separately.
           Assessed at Rs. 15,28,570/-. Charge interest u/s 158BFA for
           late filing of Return in Form 2B. Issue demand notice and

   12.The order of the CIT(A) dated 04.10.2006 inter alia, held that:
           "2.1 ...A perusal of the assessment order also shows that
           the provisions of Section 158BD were invoked on the basis
           of specific information received from D.C.I.T. Central-III,
           New Delhi. It is the satisfaction of the Assessing Officer of
           the person searched u/s 132 which is important for
           initiating proceedings u/s 158BD. As held by Gujarat High
           Court, the requirement for taking action u/s 158BD is only
           prima facie satisfaction of the Assessing Officer that in
           search operation there is material to show undisclosed
           income of a person, other than the one against whom the
           search was conducted (251 ITR 608). Hence, the argument
           of the appellant that the jurisdiction u/s 158BD had been
           invoked without any satisfaction on behalf of the Assessing
           Officer is not correct. The appeal on these grounds,
           therefore, fails.
           In the result, the appeal is dismissed."
   13.The relevant portion of the order of the ITAT dated 17.04.2009 is as

ITA 287 & 1329/2009                                                        Page 6
           "2. We have considered the rival submissions. It is noticed
           that it has been clearly held by the special bench of this
           Tribunal in the case of Bishen Chand referred to supra that
           the notice u/s 158BD has to be issued before the completion
           of the assessment in the case of the person searched. It has
           also been held that the satisfaction is to be record[ed] in the
           file of the person searched in regard to the evidence in
           respect of undisclosed income held to be belonging to the
           third party. It is notice[d] that in the present case the notice
           u/s 158BD had been issued much after the completion of the
           assessment in the case of Manoj Aggarwal. The revenue has
           also not been able to produce any evidence to show that
           satisfaction for initiation of proceedings u/s 158BD in the
           case of their assessee has been recorded in the file of either
           Shri Manoj Aggarwal or M/s. Friends Portfolio. In these
           circumstances, on both the grounds respectfully following
           decision of the Special Bench in the case of Bishan Chand
           Mukesh Kumar the assessment as completed u/s 158BD
           stands quashed."

   14.The decision in Commissioner of Income Tax v Sh. Radhey Shyam
       Bansal 2011 (337) ITR 217 (Del) dealt with the batch of cases
       decided by the impugned common order of the ITAT and upheld the
       latters order. That common judgment of this court was carried in
       appeal by special leave to the Supreme Court, which decided all the
       appeals and other cases, on the question of law as to the
       reasonableness of the time limit within which a notice under Section
       158BD was to be issued. The Supreme Court, in its judgment
       reported as CIT vs. Calcutta Knitwears, Ludhina 362 ITR 673 (SC),
       inter alia, recorded as follows:

               "44. In the result, we hold 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

ITA 287 & 1329/2009                                                           Page 7
               person under Section 158BC of the Act; (b) along with the
               assessment proceedings under Section 158BC of the Act; and
               (c) immediately after the assessment proceedingjs are
               completed under Section 158BC of the Act of the searched
               45. We are informed by Shri Santosh Krishan, who is
               appearing in seven of the appeals that the assessing officer
               had not recorded the satisfaction note as required under
               Section 158BD of the Act, therefore, the Tribunal and the High
               Court were justified in setting aside the orders of assessment
               and the orders passed by the first appellate authority. We do
               not intend to examine the aforesaid contention canvassed by
               the learned counsel since we are remanding the matters to the
               High Court for consideration of the individual cases herein in
               light of the observations made by us on the scope and possible
               interpretation of Section 158BD of the Act."
   15.The revenue argues that applying the above principles, it is clear that
       the satisfaction note recorded on 13-02-2003 in the present case, was
       not delayed. It was submitted that Calcutta Knitwears is decisive in
       that the outer period of two years meant for completion of the
       searched persons assessment is inconclusive of the time period for
       issuance of notice to the third party and that the test of proximity
       indicated by the Supreme Court is flexible in that notice under
       Section 158BD is not conditional upon simultaneous completion of
       the searched individual or concern assessment. Counsel for the
       respondent assessee did not dispute that the satisfaction note issued
       in this case met with the requirements of law, as to the adequacy or
       sufficiency of reasons recorded in the "satisfaction note". It was
       however urged that in addition to the delay in recording the
       satisfaction note, the delay in issuing the notice was also fatal to the
       block assessment proceedings drawn against the assessees in this
       case. To this end, counsel relied on the Gujarat High Court ruling in
       Khandubhai Visanji Desai & Ors. v. Deputy Commissioner of

ITA 287 & 1329/2009                                                      Page 8
       Income Tax, [1999] 236 ITR 73 (Guj), the relevant portion of which
       has been reproduced as under:
           "16. ....Once the satisfaction under s. 158BD is reached by
           the AO, there would be no valid reason for him to delay the
           issuance of the notice which ought to be issued soon after
           the satisfaction is reached and if the AO is different, he
           ought to immediately transmit the relevant material to the
           AO having jurisdiction to enable him to proceed against
           such     other     person    by    issuing    notice    under
           s. 158BC requiring him to file the return. Since the
           satisfaction that any undisclosed income belongs to any
           person other than the one with respect to whom search was
           made or books of account, documents or assets
           requisitioned, may, in many cases be reached after the AO
           starts the proceedings under s. 158BC against the person
           with respect to whom the search was made, the shift of the
           commencement point of the limitation to the date of the
           notice, which could be issued to such other person only after
           it comes to light leading to the satisfaction of the AO that
           any undisclosed income belongs to him, was fully justified
           and it was germane to the object of making block assessment
           of undisclosed income of such other person who is now
           known as a person to whom that undisclosed income
           belongs. The AO once he reaches the requisite satisfaction,
           it bound to act swiftly to proceed against such other person
           as soon as may be in reasonable time. The speed and
           despatch with which he should act is writ large on the
           connected provisions of s. 132(9A) of the Act under which
           the authorised officer who has no jurisdiction over the
           person referred to in cls. (a), (b) or (c) of sub-s. (1) of
           s. 132 has to hand over the books of account, documents and
           assets seized to the ITO having jurisdiction over such person
           within 15 days of such seizure and the AO is required to
           serve a notice to such person under s. 158BC(1) requiring
           him to furnish return in the prescribed Form 28 and to
           complete the block assessment in one year from the end of
           the month in which the last authorisation for search or
           requisition was executed. Thus, the apprehension that a
           notice can be issued under s. 158BD r/w s. 158BC (1) by the
           AO in the case of such "other person" at any time is ill-
           founded. There is no lifting of the limitation period for
           making the assessment order which is one year and the

ITA 287 & 1329/2009                                                    Page 9
           starting point of limitation in cases falling under
           s. 158BD by the very nature of things can be fixed only after
           the AO is satisfied that any undisclosed income belongs to
           such other person and in cases where the AO is different
           after the relevant material is transmitted to him. As soon as
           the AO having jurisdiction receives the material in respect
           of the other person, he is in the same position as the AO who
           forwarded it to him and is expected to immediately proceed
           to issue notice to that other person who falls in his
           jurisdiction. This extra time for computing limitation is
           warranted by the fact that the requisite satisfaction about
           any undisclosed income belonging to such other person may
           be reached after the commencement of the assessment
           proceedings against the raided person and consideration of
           the evidence forwarded by the authorised officer and
           information that may be available to the AO and transmitted
           to the other AO in cases where the other person falls in the
           jurisdiction of that other AO which will necessarily take
           some time..."
           "18. ....If in any particular case a notice is unduly delayed
           then that is a matter in which the validity of that notice can
           be considered but that surely will not invalidate the
           statutory provision which does not warrant any delay once
           the satisfaction is reached and enjoins a duty upon the AO
           to immediately proceed against such other person under the
           provisions of Chapter XIV-B."

   16.In Calcutta Knitwears, (supra), the Supreme Court inter alia,
       recorded as follows (apart from its conclusions in para 44 quoted
               "39. Further, Section 158BE (2) (b) only provides for the
               period of limitation for completion of block assessment
               under section 158BD in case of the person other than the
               searched person as two years from the end of the month
               in which the notice under this Chapter was served on
               such other person in respect of search carried on after
               01.01.1997. The said section does neither provides for
               nor imposes any restrictions or conditions on the period
               of limitation for preparation the satisfaction note under
               Section 158BD and consequent issuance of notice to the
               other person."

ITA 287 & 1329/2009                                                    Page 10
               *****************                      ***************

               42. Further, Section 158BE(2)(b) only provides for the
               period of limitation for completion of block assessment
               under section 158BD in case of the person other than the
               searched person as two years from the end of the month
               in which the notice under this Chapter was served on
               such other person in respect of search carried on after
               01.01.1997. The said section does neither provides for
               nor imposes any restrictions or conditions on the period
               of limitation for preparation the satisfaction note under
               Section 158BD and consequent issuance of notice to the
               other person.

               43. In the lead case, the assessing officer had prepared a
               satisfaction note on 15.07.2005 though the assessment
               proceedings in the case of a searched person, namely,
               S.K. Bhatia were completed on 30.03.2005. As we have
               already noticed, the Tribunal and the High Court are of
               the opinion that since the satisfaction note was prepared
               after the proceedings were completed by the assessing
               officer under Section 158BC of the Act which is contrary
               to the provisions of Section 158BD read with Section
               158BE(2)(b) and therefore, have dismissed the case of
               the Revenue. In our considered opinion, the reasoning of
               the learned Judges of the High Court is contrary to the
               plain and simple language employed by the legislature
               under Section 158BD of the Act which clearly provides
               adequate flexibility to the assessing officer for recording
               the satisfaction note after the completion of proceedings
               in respect of the searched person under Section 158BC.
               Further, the interpretation placed by the Courts below by
               reading into the plain language of Section 158BE(2)(b)
               such as to extend the period of limitation to recording of
               satisfaction note would run counter to the avowed object
               of introduction of Chapter to provide for cost effective,
               efficient and expeditious completion of search
               assessments and avoiding or reducing long drawn

       Earlier in the judgment the date on which notice was issued to the
       third party under Section 158 BD in that case was recorded:

ITA 287 & 1329/2009                                                      Page 11
               "The jurisdictional assessing authority for the
               respondent-assessee had issued the show cause notice
               under Section 158BD for the block period 01.04.1996 to
               05.02.2003, dated 10.02.2006 to the assesse inter alia
               directing the assessee to show cause as to why should the
               proceedings under Section 158BC not be completed."

   17.The application of Calcutta Knitwears was the subject matter of a
       recently decided case, i.e., Commissioner of Income Tax v. V.K.
       Narang HUF, ITA 1064/2009 (decided on 08.01.2015) where it was
       observed that:
           "4. Having regard to the decision in CIT v. Manish
           Maheshwari (2007) 289 ITR 341 (SC) this Court is of the
           opinion that the satisfaction note in the present case meets
           with the requirements of law. So far as the question of delay
           is concerned, the Court is of the opinion that in the facts and
           circumstances of the present case, it cannot be held that
           there was any delay in recording the satisfaction note. The
           assessment of the searched person was completed on
           31.12.2001. The satisfaction note was recorded on
           30.05.2002 i.e. just about five months after the date of
           completion of searched person. Notice was issued on
           03.06.2002, immediately after the satisfaction note was
           recorded to the present assessee."

           5. Having placed due regard to the declaration of law made
           by the Supreme Court which specified three possible points
           in time when notice under Section 158BD can be issued to
           third party/assessee, on the basis of material found on the
           premises of the searched person, the period of five months
           spent by the AO of the searched person in finalizing the
           satisfaction note, can be said to have been proximate to the
           assessment proceedings. We also recollect the decision of
           this Court in Commissioner of Income Tax v. Raghubir
           Singh Garg ITA No. 1420/2010 decided on 27.08.2014. In
           that case, the search took place on 29.08.2002 and the
           satisfaction note was recorded on 16.01.2003 i.e. within a
           period of 4 ½ months. The Court was of the opinion that the
           satisfaction note could be upheld. Following the said
           decision it is held that there was no delay in issuance of
           notice under Section 158BD in the facts of the case."

ITA 287 & 1329/2009                                                     Page 12
   18.In light of the aforementioned position of law this Court finds that
       the delay of 5 months in the issuing of notice by the A.O. in the
       present appeals cannot be unreasonable. Accordingly, the impugned
       orders of the ITAT dated 04.04.2008 & 17.04.2009 is set aside on
       this aspect. The satisfaction note is held to be validly issued and
       within a reasonable time. In the light of the above observations of the
       Supreme Court in Calcutta Knitwears, particularly the contextual
       facts discussed (i.e. completion of the searched partys assessment on
       31-03-2005, satisfaction note under Section 158BD issued on 15-07-
       2005 and notice issued on 10-02-2006) it cannot be said that the
       delay in issuing the notice (although the satisfaction note was
       recorded within reasonable time) was fatal to the block assessment
       against the present assesse.
   19.The Court notices that the ITAT by its order dated 04.04.2008 in CIT
       v. Sudhir Dhingra has not dealt with the merits of the Revenues
       contentions with regards to the challenge to the order of the Ld. CIT
       (A). This is especially reflected from a reading of the judgment
       which has solely proceeded on the question of delay in the issuance
       of notice under Section 158BD. In the same vein the court also finds
       that the order of the ITAT dated 17.04.2009 in Renu Verma v. CIT
       has also been decided on the similar issue of delay. In these
       circumstances, these two appeals are accordingly remitted to the
       ITAT to decide their respective contentions on merits, on the facts of
       the case, and as to the correctness or otherwise of the additions made
       by the AO of the present assessees. Considering that the satisfaction
       note and notice were issued in 2003, the ITAT shall consider and
       decide these appeals expeditiously. The rights and contentions of the

ITA 287 & 1329/2009                                                    Page 13
       parties shall not be prejudiced. The appeals are partly allowed in the
       above terms.

                                                   S. RAVINDRA BHAT

                                                       R.K. GAUBA
       JANUARY 30, 2015

ITA 287 & 1329/2009                                                   Page 14
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