Section 153C jurisdiction requires a specific satisfaction note linking seized material to the relevant assessment year.

Section 153C jurisdiction depends on a prior satisfaction note linking identified incriminating material to the total income of the specific assessment year sought to be assessed. A general reference to seized documents, broad scrutiny, or revenue leakage concerns is insufficient unless the material is shown to have a bearing on that year's assessment. Where the satisfaction note does not connect the seized material to the relevant year and its income impact, the statutory precondition fails and proceedings under section 153C are invalid. On that basis, the jurisdictional challenge succeeded and the assessment was quashed.

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Issues: (i) Whether the notice and assessment under section 153C of the Income-tax Act, 1961 were valid in the absence of a satisfaction note showing that the seized material had a bearing on the assessment year in question.

Analysis: The jurisdiction under section 153C requires prior satisfaction that the material received is likely to have a bearing on the determination of the total income of the specific assessment year sought to be assessed. A general reference to seized documents, "deep scrutiny," or a need to plug revenue leakage is insufficient. The satisfaction recorded must link the incriminating material to the relevant assessment year and indicate how it impacts that year's income; otherwise the statutory preconditions for invoking section 153C are not met.

Conclusion: The jurisdictional requirement was not satisfied, and the initiation of proceedings under section 153C was invalid.

Final Conclusion: The additional ground challenging jurisdiction succeeded, and the assessment was quashed.

Ratio Decidendi: Proceedings under section 153C can be initiated only when the jurisdictional Assessing Officer is satisfied, on the basis of identified incriminating material, that the material is likely to have a bearing on the total income of the specific assessment year concerned.

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