Assessment u/s. 153C of the Act was initiated on the basis of Satisfaction Note recorded by the AO, who was having jurisdiction over both the searched person and person other than the searched person. Satisfaction Note did not refer to the material seized during the course of Search u/s. 132 of the Act. Tribunal held that single consolidated satisfaction note could be prepared for more than one AY but AO should record satisfaction that which incriminating material pertains to which AY’s to depict application of mind and initiation of action under section 153C of the Act qua such assessment years. In absence of the same, assessment order passed u/s. 153C of the Act were quashed by the Delhi Tribunal. (AY.  2019-20)