Dismissing the appeal of the revenue the Court held that statute mandates that a satisfaction note has to be recorded by the AO. Office note at best can be treated to be a speculation and cannot qualify to be a valid satisfaction note.  On the factual aspect, the Tribunal has rendered a finding in favour of the assessee and this finding of fact cannot be allowed to be reopened by the Revenue. Further, initiation of the proceedings under s. 158BD pursuant to a letter dt. 5th Aug., 2003 issued by the AO of the searched person is barred by time as it is almost a year after the block assessment was completed on the searched person on 28th Aug., 2002. (AY. 1991-92 to 2001-02)