Dismissing the appeal of the assesse the Court held that ; although S. 158BD does not speak of ‘recording of reasons’ as postulated in S. 148, but since proceedings u/s 158BD may have monetary implications, such satisfaction must reveal mental and dispassionate thought process of the AO in arriving at a conclusion and must contain reasons which should be the basis of initiating the proceedings u/s 158BD. Notice u/s 158BC issued on the same date to the searched person and the other person is not valid as no reasonable or prudent man can come to the satisfaction that any undisclosed income belongs to the other person unless the seized books of accounts etc are verified. The AO is empowered to issue a second notice u/s 158BD to the other person . Accordingly the order of High court was affirmed . ( CA No. 2014 of 2007, dt. 24.04.2018)( AY. 1989-90 to 1999-2000)