Section 153C satisfaction requirement remains mandatory before using seized material for another person's assessment.

Section 153C confers jurisdiction only after the Assessing Officer of the searched person first records satisfaction that seized money, books, documents or assets belong to or relate to another person, and then hands over that material for separate assessment. That precondition remains mandatory even where the same officer assesses both persons. Applying Calcutta Knitwears and the CBDT circular, the text notes that an order-sheet entry in the assessee's file before notice did not satisfy the required prior satisfaction in the searched person's case. The assessment under section 143(3) read with section 153C was therefore invalid and was quashed.

---

---

Issues: Whether the assessment framed under section 143(3) read with section 153C was valid in the absence of satisfaction recorded by the Assessing Officer of the searched person before handing over seized material relating to the assessee.

Analysis: Section 153C requires a satisfaction that seized money, books of account, documents or assets belong to or relate to a person other than the searched person, followed by handing over of such material and a further satisfaction before assessment of the other person. The requirement is jurisdictional and is not dispensed with merely because the Assessing Officer of the searched person and the other person is the same. The decision in Calcutta Knitwears and the CBDT circular were applied to hold that separate satisfaction by the searched person's Assessing Officer is mandatory. On the facts, the only note produced was an order-sheet entry in the assessee's file before issue of notice, which did not satisfy the statutory precondition of prior satisfaction in the searched person's case.

Conclusion: The assessment under section 143(3) read with section 153C was invalid and was quashed for all the assessment years in question.

Ratio Decidendi: The jurisdiction under section 153C can be assumed only when the Assessing Officer of the searched person first records the required satisfaction that seized material belongs to or relates to another person, and this prerequisite remains mandatory even where the same officer assesses both persons.

---