Petitioner challenged notice under Section 153C for Assessment year 2017-18 on ground that satisfaction was not recorded at any permissible stage and, in any case, was not recorded “immediately after” completion of searched person’s assessment. Department attributed the delay to COVID-19 and the Faceless Assessment Scheme. It was noted that though the Assessing Officer had an opportunity to record a satisfaction note at two stages as specified in Circular No. 24/2015 but same was not done. Further, search was conducted on 15-10-2019, searched person’s assessment was completed in August 2021. Satisfaction note was recorded on 6-6-2023 by the Assessing Officer of the searched person, which was forwarded to the Assessing Officer of petitioner, who in turn recorded a satisfaction note on 17-10-2023. Since there was a delay of 22 months in recording the satisfaction note, which ran contrary to the decision in CIT v. Calcutta Knitwears [2014] 43 taxmann.com 446/223 Taxman 115/362 ITR 673 (SC) as well as provision ‘(c)’ of Circular No.24/2015, the notice under Section 153C was quashed. (AY. 2017-18)