JUDGMENT : M.R. Shah, J. 1. As common question of law and facts arise in both these Tax Appeals and as such are with respect to the same assessee but different Assessment Years and as such arising out of the impugned common judgment and order passed by the learned Income Tax Appellate Tribunal, both these Tax Appeals are decided and disposed of together by this common judgment and order. 2. Feeling aggrieved and dissatisfied with the impugned common judgment and order passed by the learned Income Tax Appellate Tribunal Ahmedabad "B" Bench, Ahmedabad (hereinafter referred to as "the learned tribunal") dated 31/05/2016 in IT(SS)A No. 258/Ahd/2013 for the Assessment Year 2007-08 and in IT(SS)A No. 259/Ahd/2013 for the Assessment Year 2008-09, revenue has preferred the present Tax Appeals with the following proposed question of law; "Whether the Hon'ble ITAT is right in law and on facts in quashing the proceedings initiated by the AO under Section 153C and holding that no common or separate satisfaction in the case of searched person Shri Vikas R. Patel before initiating Section 153C proceedings though the separate satisfaction note was recorded by the AO in the assessee's case?" 3. The search and seizure action was carried out under Section 132 of the Income Tax Act (hereinafter referred to as "the Act") in the premises of one Vikas R. Patel on 04/03/2010. Certain incriminating documents were seized at the premises of the concerned respondent - assessee during the course of search. Thereafter notice was issued under Section 153C of the Act for the Assessment Years 2007-08 and 2008-09. The Assessing Officer completed the assessment under Section 153C of the Act determining the taxable income of the assessee for the years under consideration. The same came to be confirmed by the learned CIT(A) in Appeals preferred by the assessee. In further Appeals, relying upon the decision of the Division Bench of this Court in the case of DCIT Central Circle 1 - Baroda v. Lalitkumar M. Patel rendered in Tax Appeal No. 192/2012 and having found and observed that there was no separate satisfaction in the case of the search person, Shri Vikas R. Patel before initiating 153 proceedings, the learned tribunal has allowed the Appeals preferred by the assessee and has set aside the orders passed under Section 153C of the Act. Feeling aggrieved and dissatisfied with the impugned common judgment and order passed by the learned tribunal, revenue has preferred the present Tax Appeals with the aforesaid proposed question of law. 4. We have heard Shri Nitin Mehta, learned Counsel appearing on behalf of the revenue and Shri S.N. Divetia, learned advocate appearing on behalf of the assessee at length. It is not disputed that the search was carried out at the premises and in the case of one another person, Shri Vikas R. Patel. There was no satisfaction recorded by the Assessing Officer in the case of the searched person, Shri Vikas R. Patel before initiating Section 153 proceedings, and therefore, the mandatory requirement, before initiating the proceedings under Section 153C of the Act in the case of the assessee (other than the searched person) has not bee followed. It was the case on behalf of the revenue that separate satisfaction note was recorded by the Assessing Officer. However, as per catena of decisions of the Hon'ble Supreme Court as well as this Court, same is not sufficient to initiate the proceedings under Section 153C of the Act in the case of the assessee (other than the searched person). As such, the issue involved in the present Appeals are squarely covered by the decision of the Hon'ble Supreme Court in the case of Manish Maheswari v. Asst. Commissioner of Income Tax & Another reported in [2007] 289 ITR 341 (SC); in the case of Khandubhai Vasanji Desai & Others v. Deputy Commissioner of Income Tax & Another reported in 236 ITR 73 (Gujarat) and in the case of Commissioner of Income Tax v. Champakbhai Mohanbhai Patel reported in [2015] 370 ITR 700 (Gujarat). While passing the impugned common judgment and order, the learned tribunal has relied upon the decision of the Division Bench of this Court in the case of Lalitkumar M. Patel (Supra) and relying upon the said decision the assessment orders under Section 153C in the case of the assessee (other than the searched person) are set aside. We see no reason to interfere with the impugned judgment and order passed by the learned tribunal and as such no substantial question of law arises in the present Tax Appeals. 4.1. We see no reason to interfere with the impugned judgment and order passed by the learned tribunal and as such no substantial question of law arises in the present Tax Appeals. 4.1. At this stage, it is required to be noted that even the CBDT has also issued Circular No. 24/2015, in which it is observed that recording of satisfaction note is prerequisite and the satisfaction note must be prepared by the AO before he transmits the record to the other AO who has jurisdiction over such other person. Despite the above, Department has preferred Appeals. Be that as it may, as observed hereinabove, no substantial question of law arise in the present Appeals and the present Appeals deserve to be dismissed and are accordingly dismissed.