Section 132 & 153C of the Income Tax Act, 1961 — Search and Seizure — There was no good reason to interfere with the concurrent findings recorded by the two appellate authorities as regards the satisfaction arrived at by the AO without there being any cogent or tangible material. There must be some cogent material available with the AO before he arrives at the satisfaction that the seizer document does not belong to the searched person but to a third person. Surmise and conjecture cannot take the place of satisfaction — Principal Commissioner of income tax vs. Himanshu Chandulal Patel [2019] 419 ITR 132 (Gujarat).