Court held that it is evident that satisfaction can even be recorded immediately after completion of the assessment proceedings under Section 158BC. In the instant case, admittedly, the satisfaction has been recorded after completion of the proceedings under Section 158BC. However, the order passed by the Assessing Officer as well as the Commissioner of Income Tax (Appeals) has been set aside by the Tribunal merely on the ground that the satisfaction has not been recorded before completion of the assessment proceedings. The aforesaid finding is contrary to law laid down by the Supreme Court in the case of  of CIT v . Calcutta Knitwears (2014) 362 ITR 673 (SC  Therefore, the same cannot be sustained in the eye of law.Court also held that a satisfaction note is sine qua non and could be prepared at either of following stages , at the time of or along with the initiation of proceedings against the person searched under section 158BC of the Act , along with the assessment proceedings under section 158 BC and immediately after the assessment proceedings are completed under section 158BC of the person searched . Order of Tribunal is quashed .Court also held that a satisfaction note is sine qua non and could be prepared at either of following stages , at the time of or along with the initiation of proceedings against the person searched under section 15C of the Act , along with the assessment proceedings under section 158 BC and immediately after the assessment proceedings are completed under section 158BC of the person searched . Order of Tribunal is quashed .