Sec. 158BC of Income Tax Act, 1961—Search & Seizure—A harmonious and combined reading of Sections 158BC and 158 BD is necessary to give effect to the Scheme of Assessment in the case of Search undertaken against the Assessee to bring to tax the Undisclosed Income under Chapter XIVB of the Act. It is true that the Assessing Authority should record such satisfaction at initial stage itself when the proceedings of Assessment under Section 158BC are undertaken against the person, on whom Search is conducted and if it is found that the seized documents were the material pertaining to the third party or other person, then, after recording of such satisfaction, such third party or other person can be proceeded against under Section 158BD and then the Provisions under Section 158BC and Chapter XIVB would apply to such third party. But, once the Tribunal finally concluded the finding of fact in the case of persons against whom search was made that the transaction of sale of property in question was taxable in the hands of mother-present Assessee, non-recording of reasons independently by the Assessing Authority, assuming it to be so, though there is nothing on record to indicate otherwise, cannot be said to be fatal for initiating proceedings under Section 158BD against the mother-present Assessee — VIJAYALAKSHMI (V.)(SMT.) Vs. DEPUTY CIT  [2020] 421 ITR 562 (MAD)