Where AO having jurisdiction over searched person and other than searched person is same In the case where the AO of the searched person as well as the other person is one and the same, the date on which such satisfaction is recorded would be the date on which the AO assumes possession of the seized assets/documents in his capacity as an AO of the person other than the one searched.[Para 18 2nd line] Allahabad High Court in the case of Commissioner of income Tax v. Gopi Apartments: [2014] 360 ITR 411 “26. Even in a case, where the Assessing Officer of both the persons is the same and assuming that no handing over of documents is required, the recording of 'satisfaction' is a must, as, that is the foundation, upon which the subsequent proceedings against the 'other person' are initiated. The handing over of documents etc. in such a case may or may not be of much relevance but the recording of satisfaction is still required and in fact it is mandatory." Madhya Pradesh High Court in Commissioner of Income Tax v. Mechmen: [2015] 60 taxmann.com 484 (Madhya Pradesh) also suggested the same Delhi High Court Judgement in RRJ Securities Ltd [2015] 62 taxmann.com 391 (Delhi) 30-10-2015