Satisfaction that undisclosed income belongs to some person other than person searched needs to be recorded by AO

From the noted portion of the Tribunal’s impugned judgment, it clearly emerges that no such satisfaction was recorded by the Assessing Officer of the searched person. At any rate, no such satisfaction was produced before the Tribunal. In fact the Tribunal found that the satisfaction recorded for issuance of notice was by the Assessing Officer of the present respondent and not by the Assessing Officer of the person who was subjected to search. Such recording of satisfaction and issuance of notice were also long after the last date for completion of the assessment. We also notice that in f...