- (1.) This appeal under section 260A of the Income-Tax Act, 1961 (for short ''the Act''), has been filed by the Revenue against the order dated June 25, 2010, passed by the Income-Tax Appellate Tribunal, Chandigarh Bench ''B'', Chandigarh (in short ''the Tribunal'') in ITSS(A) No. 5/Chandi/2010, for the block period from April 1, 1998, to February 5, 2003.
(2.) The following substantial question of law has been claimed for determination of this court : Whether, on the facts and in law, the honble Income-Tax Appellate Tribunal was justified in holding the recording of satisfaction under section 158BD by the assessing officer of the person searched and consequent issuance and service of notice under section 158BD on December 8, 2005, was belated and beyond the period prescribed by law when section 158BD read with section 158BE does not specify that satisfaction has to be recorded by the assessing officer before completion of assessment under section 158BC of the Income-Tax Act, 1961.
(3.) The facts, in brief, necessary for adjudication as narrated in the appeal, are that the respondent-assessee is an individual who is carrying on business of manufacturing of hosiery goods. On February 5, 2003, a search operation under section 132(1) of the Act was carried out at the residence of one S. K. Bhatia, a yarn dealer. During the course of the search, certain loose documents were seized which related to two business concerns of S. K. Bhatia, viz., M/s. Swastik Trading Co. and M/s. Kavita International agencies. It was found that the entries recorded in those documents had not been incorporated in the books of account of the aforesaid two concerns. It was revealed from the seized documents that the assessee had made purchases worth Rs. 7,44,900 from M/s. Swastik Trading Co. and of Rs. 2,24,000 from M/s. Kavita International Agencies on different dates during the financial years 2001-02 and 2002-03.;