Section 153C jurisdiction fails when seized material is not shown to belong to the assessee and no incriminating material supports additions.

Initiation of proceedings under section 153C was held invalid where the satisfaction note did not identify any seized material as belonging to the assessee. The seized laptop was found at the searched person's premises, and the statutory presumptions under section 132(4A) and section 292C attached only to the person searched. Because the search predated 01.06.2015, the unamended section 153C applied, and no incriminating material was referred to in support of the addition. On that basis, the assessment orders were liable to be quashed.

---

---

Issues: Whether initiation of proceedings under section 153C was valid in the absence of material found during search establishing that the seized item belonged to the assessee, and whether the assessment could stand where no incriminating material was referred to for the addition made.

Analysis: The seized laptop was found from the premises of the searched person, and the satisfaction note did not refer to any seized material belonging to the assessee. The unamended version of section 153C applied to the search conducted prior to 01.06.2015. The statutory presumption under section 132(4A) and section 292C attached to the person searched, and the assessment order also did not disclose any incriminating material supporting the addition.

Conclusion: The assumption of jurisdiction under section 153C was invalid and the assessment orders were liable to be quashed.

---