Satisfaction that undisclosed income belongs to some person other than person searched needs to be recorded by AO having jurisdiction over persons searched:

A search action was conducted at the premises of one Acharya Group of persons from where certain documents in respect of undisclosed income of the present assessee were found. AO having jurisdiction over persons searched handed over the said documents to the AO having jurisdiction over the present assessee who in turn, recorded his satisfaction as regards undisclosed income for issuance of notice. As per Section 158BD, such satisfaction needs to be recorded by AO having jurisdiction over persons searched. It was held that since the AO having jurisdiction over persons searched had not recorded the satisfaction that the undisclosed income belonged to the present assessee, the proceedings against the present assessee were not valid.

[M/S. JYOTI SALT INDUSTRIES C/O JAGDISH R. ACHARYA - TAX APPEAL NO.1040 of 2011 - GHC]