IN THE PUNJAB & HARYANA HIGH COURT AT CHANDIGARH ITA No.218 of2011 Date of Decision: 22.11.2011 Commissioner of Income Tax (Central), Ludhiana …Appellant Versus M/s Davinder Sandhu Impex Ltd., Ludhiana …Respondent CORAM: HON’BLE MR. JUSTICE HEMANT GUPTA HON’BLE MR. JUSTICE G.S.SANDHAWALIA Present: Mr. Rajesh Katoch, Advocate, for the appellant-revenue. HEMANT GUPTA, J. (Oral) The Revenue is in appeal under Section 260-A of the Income Tax Act, 1961 aggrieved against an order passed by the Income Tax Appellate Tribunal, Chandigarh Bench ‘A’, Chandigarh (for short ‘the Tribunal’) on 12.10.2010 in respect of the block period 01.04.1996 to 05.02.2003. The Tribunal has relied upon an order passed by this Court in ITA No.591 of 2009 titled ‘Commissioner of Income Tax-I, Ludhiana Vs. Mridula, Prop. M/s Dhruv Fabrics, Ludhiana’ (decided on 20.07.2010). The Revenue has claimed the following substantial question of law, as arisen from the order of the Tribunal: “Whether on the facts and circumstances of the case, the Hon’ble ITAT was right in law in holding that the assumption of jurisdiction under Section 158BD of the I.T. Act by the A.O. was not valid as the satisfaction was recorded by the A.O. of the person searched after framing the block assessment under Section 158BC in the case of that person?” Learned counsel for the appellant submits that the question of law as raised by the Revenue stands concluded against the Revenue by the judgment of this Court in ITA No.591 of 2009 titled ‘Commissioner of ITA No.218 of 2011 Income Tax-I, Ludhiana Vs. Mridula, Prop. M/s Dhruv Fabrics, Ludhiana’ (decided on 20.07.2010). In view of the above, we do not find that any question of law arises for consideration by this Court. Dismissed. (HEMANT GUPTA) JUDGE 22.11.2011 (G.S.SANDHAWALIA) Vimal JUDGE 2