Section 153C jurisdiction fails without valid satisfaction and is barred by the post-01.04.2021 statutory cut-off.

Section 153C proceedings require the Assessing Officer to record valid satisfaction that seized material pertains to the other person and has a bearing on that person's total income. The note here did not record that statutory linkage, so the jurisdictional condition was not met and initiation could not be sustained. The text also applies the post-amendment cut-off: where the relevant date for initiation is the receipt of seized material, and that date fell after 01.04.2021, section 153C was barred for searches covered by the exclusion. On both grounds, the assumed jurisdiction failed and the assessments were quashed.

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Issues: (i) Whether proceedings initiated under section 153C were valid when the satisfaction note was recorded on 03.12.2021, after the amendment that made section 153C inapplicable to searches initiated on or after 01.04.2021; (ii) Whether the satisfaction recorded under section 153C was invalid for not stating that the seized material had a bearing on the determination of the total income of the assessee.

Issue (i): Whether proceedings initiated under section 153C were valid when the satisfaction note was recorded on 03.12.2021, after the amendment that made section 153C inapplicable to searches initiated on or after 01.04.2021.

Analysis: The first proviso to section 153C(1) treats the date of receipt of seized material by the Assessing Officer of the other person as the relevant date for initiation of proceedings against that person. On the facts, that date was 03.12.2021. Since section 153C(3) excludes searches initiated on or after 01.04.2021, the statutory bar applied. The notices issued under section 153C and the consequent assessments could not be sustained in law.

Conclusion: The initiation of proceedings under section 153C was invalid and without jurisdiction.

Issue (ii): Whether the satisfaction recorded under section 153C was invalid for not stating that the seized material had a bearing on the determination of the total income of the assessee.

Analysis: For jurisdiction under section 153C, the Assessing Officer must record satisfaction that the seized books, documents, or assets pertain to the other person and have a bearing on the determination of that person's total income. The satisfaction note did not record this statutory linkage. In the absence of such recorded satisfaction, the jurisdictional precondition remained unmet.

Conclusion: The satisfaction note was not valid and could not support initiation of proceedings under section 153C.

Final Conclusion: The jurisdiction assumed under section 153C failed on both the statutory cut-off issue and the absence of a valid recorded satisfaction, so the assessments were quashed for all three assessment years.

Ratio Decidendi: Proceedings under section 153C can be initiated only when the jurisdictional Assessing Officer records a valid satisfaction that the seized material pertains to the other person and has a bearing on the determination of that person's total income, and such proceedings are barred where the statutory exclusion for searches initiated on or after 01.04.2021 applies.

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