There is a vital distinction between the object, intention as well as the express language of sections 153A and 153C.Section 153C  requires the satisfaction of two conditions prior to issuance of notice, (i) recording of satisfaction by the Assessing Officer of the searched entities that some of the incriminating materials relate to a third party, and (ii) recording of satisfaction by the Assessing Officer of the third party that the incriminating materials have a bearing on the determination of the total income of that third party. Notice under section 153C would have to be issued only upon the concurrent satisfaction of both these conditions.The court made it clear that the appellate authority should make good the error committed by the assessing authority by ensuring that an effective opportunity of cross-examination was granted to the assessee prior to finalising the appeal proceedings. The powers of the appellate authority under sections 246 and 246A are co-terminus with those of the Assessing Officer and the direction would suffice to protect the interests of the assessees and to remedy the procedural error committed by the officer while framing the assessment.](AY.2009-10, 2011-12, 2012-13, 2013-14 to 2019-20)