Year-specific incriminating material is essential for Section 153C jurisdiction; unsupported notices were quashed.

Section 153C of the Income-tax Act can be invoked only when the jurisdictional Assessing Officer is satisfied that seized or requisitioned material has a bearing on the total income of the specific assessment year or years sought to be reopened. The material must be linked to those years; a broad invocation for multiple years is not justified where the satisfaction note relates only to other years and no incriminating material is found for the years covered by the notices. On that basis, the notices and consequential proceedings were held invalid and quashed, and the writ petitions succeeded.

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Issues: Whether notices issued under Section 153C of the Income-tax Act, 1961 for the concerned assessment years were valid when the satisfaction note related only to incriminating material concerning other assessment years and no material was found for the years covered by the notices.

Analysis: Section 153C permits issuance of notice and resulting abatement only when the jurisdictional Assessing Officer is first satisfied that the seized or requisitioned material is likely to have a bearing on the determination of total income for the particular assessment year or years sought to be reopened or assessed. The material must be identified with the assessment year to which it relates or is likely to impact. A sweeping invocation of the provision for multiple years is not justified merely because the statute permits assessment of a block period. Where the satisfaction note itself shows that the incriminating material pertains to different years and there is no material for the assessment years covered by the impugned notices, jurisdiction under Section 153C is not established.

Conclusion: The notices under Section 153C and the consequential proceedings were invalid and were quashed in favour of the assessee.

Final Conclusion: The writ petitions succeeded and the impugned reassessment machinery under Section 153C could not be sustained for the assessment years for which no incriminating material was shown.

Ratio Decidendi: Jurisdiction under Section 153C arises only when the seized or requisitioned material is first found, on the jurisdictional Assessing Officer's satisfaction, to have a bearing on the determination of total income for the specific assessment year or years sought to be proceeded against.

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