However, the Section 153C satisfaction was recorded only on 24.12.2021, notices under Section 153C were issued on 28.12.2021, and the assessments were ultimately completed on 30.03.2023. Therefore, for limitation purposes, the Revenue could not rely upon the much later date of recording the satisfaction note. 143(3) assessments itself framed by the learned Assessing Officer on 30.03.2023 as barred by limitation. person other than searched person, hence, a satisfaction note was drawn on 28.06.2022 to initiate proceedings u/s 153C r.w.s. It may so happen that the Assessing Officer of the searched person is different from the Assessing Officer of the other person and in the second eventuality, the Assessing Officer of the searched person and the other person is the same.