AO to record satisfaction regarding existence of undisclosed income before proceeding u/s. 153C of the Act

Beejay Security & Finance Ltd. Vs ACIT (ITAT Mumbai)- Satisfaction is required to be arrived at by the AO of the person who was searched under s 132 of the Act regarding any undisclosed income of the person who was not subjected to a search to hand over the seized material to the AO of the person to whom the seized documents belongs or is alleged to belong.  The satisfaction required for proceedings under s 153C cannot be reduced to a mere formality of forwarding the documents found in the course of the search, which did not belong to the person searched, and which belonged to the perso...