Year-wise satisfaction under section 153C is essential; a consolidated satisfaction note can invalidate jurisdiction.

Section 153C jurisdiction was examined on the basis of a common satisfaction note covering assessment years 2012-13 to 2018-19. The Tribunal's view was that satisfaction must be recorded year-wise for the relevant assessment year, and that a consolidated note for multiple years vitiates the assumption of jurisdiction. Because the jurisdictional challenge went to the root of the proceedings, the additions were treated as academic. On that basis, the combined satisfaction note was said to invalidate the section 153C proceedings and the assessment was quashed.

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Issues: Whether the assessment initiated under section 153C was valid when the satisfaction note covered multiple assessment years together instead of recording separate satisfaction for each year.

Analysis: The assessment was founded on a common satisfaction note recorded for assessment years 2012-13 to 2018-19. The Tribunal applied the view that section 153C requires satisfaction to be recorded year-wise for the relevant assessment year, and that a consolidated satisfaction note for several years vitiates the assumption of jurisdiction. Since the legal challenge went to the root of the proceedings, the merits of the additions were treated as academic.

Conclusion: The combined satisfaction note rendered the proceedings under section 153C invalid, and the assessment was quashed. The challenge succeeded in favour of the assessee.

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