Dismissing the appeal of the Revenue the Court held that  the Tribunal was right in law in holding that the AY. relevant to the financial year in which satisfaction note was recorded under section 153C of the Act, would be taken as the year of search for the purposes of clauses (a) and (b) of sub-section (1) of section 153A of the Act by making reference to the first proviso to sub-section (1) of section 153C. Therefore, the Tribunal was right in law in holding that no satisfaction was recorded by the Assessing Officer of the searched person and the notice issued by the Assessing Officer under section 153C of the Act would be taken as the year of search for the purpose of clauses (a) and (b) of sub-section (1) of section 153A. The Tribunal was right in law in setting aside the assessment order passed for the AY. 2011-12 under the facts and circumstances of the case holding that there was no satisfaction recorded by the Assessing Officer of the searched person in so far as section 153A in the case of the assessee. Referred, CIT v. Gopi Apartment (2014) 365 ITR 411 (All)(HC) (AY. 2011-12)