Held  that the pre-amended law under section 153C of the Act needed to be applied since the date of search was on October 27, 2014, and that date had to be considered to be relevant date for the purpose of applying the provisions of section 153C(1) of the Act, even though the satisfaction note was handed over to the Assessing Officer of the assessee on March 15, 2017. The essential jurisdictional fact for initiation of assessment under section 153C of the Act according to the pre-amended section 153C of the Act was that the Assessing Officer of the person in respect of whom search was conducted should be able to return a finding of fact that the seized material belonged to the assessee and thereby rebutting the presumption that documents seized belongs to searched party. On perusal of the satisfaction note, though the Assessing Officer said that the seized documents belonged to the assessee, these were merely ledger accounts of the assessee maintained by the person in respect of whom search was conducted in its books, i. e., Nalini J. Vyas. Therefore, the satisfaction note prepared at the first stage by the Assessing Officer of the person in respect of whom search was conducted in respect of the assessee for initiation of proceedings under section 153C of the Act did not satisfy the requirement of the law and consequently all actions taken pursuant thereto by the Assessing Officer of the assessee was void ab initio. That all the quantum assessments under section 153C of the Act pertaining to the assessment years 2010-11, 2011-12 and 2012-13 were to be quashed.  In the light of quashing the assessments framed under section 153C for the assessment years 2010-11, 2011-12 and 2012-13, the penalty levied based on those assessments, had to fall. Therefore, the penalty for all the appeals needed to be cancelled.(AY.2010-11 to 2012-13)