Recorded satisfaction in seized-document cases remains a factual issue where the Tribunal finds no link to the assessee.

The Tribunal found that the Assessing Officer had not recorded the requisite satisfaction linking the income in the seized documents to the assessee. That absence of recorded satisfaction was treated as a factual finding, not a legal error. On that basis, the appellate court held that no substantial question of law arose from the Tribunal's conclusion, so the appeal was not fit for further consideration.

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Issues: Whether the Assessing Officer had recorded the requisite satisfaction that the income reflected in the seized documents belonged to the assessee, and whether any substantial question of law arose from the Tribunal's finding on that issue.

Analysis: The Tribunal found, on the material before it, that the Assessing Officer had not recorded satisfaction linking the income noted in the seized documents to the assessee. The absence of such recorded satisfaction was treated as a factual determination. On that basis, the matter did not give rise to any substantial question of law for consideration in appeal.

Conclusion: No substantial question of law arose. The appeal was therefore liable to be dismissed.

Ratio Decidendi: Where the appellate fact-finding authority records that the Assessing Officer did not note the necessary satisfaction on the material before him, the issue remains one of fact and does not, by itself, raise a substantial question of law.

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