Kakanatil Abdul Rahiman Siraj Mather vs Assistant Commissioner Of Income Tax on 15 December, 2025
5. Per contra, Sri.Navaneeth, the learned Standing Counsel,
would contend that a satisfaction was recorded by the AO of the
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ITA No.84 of 2025 and con.cases 2025:KER:96474
searched person, and insofar as the AO of the searched person and the
appellant herein are one and the same, there is no requirement for
recording satisfaction with respect to the AO of the "other person". He
would also rely on Mohammed Sherief (supra) in support of this
contention. In reply, Sri.Asokan would contend that while the searched
person was at Calicut, the appellant was at Ernakulam, and the AOs
were not the same officers.