Section 153C jurisdiction depends on incriminating material and a proper satisfaction note; assessments were quashed as invalid.

Assessments under section 153C require material belonging to or relating to the assessee, a bearing on total income, and a recorded satisfaction note before jurisdiction can be assumed. The text states that the relevant years were unabated, the additions were based on material from an earlier search in another case rather than incriminating material seized in the assessee's search, and no proper satisfaction note was shown. On that basis, the assessments were treated as invalid and quashed, so the additions did not survive.

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Issues: Whether the assessments framed under section 153C of the Income-tax Act, 1961 for the two assessment years were valid when the additions were not based on incriminating material found in the search on the assessee group and no proper satisfaction note was shown to have been recorded.

Analysis: The assessee's years were unabated on the date of the notice under section 153C. The additions were founded on material and information said to have emerged from an earlier search in another case, rather than on any incriminating material seized in the search relatable to the assessee. For assumption of jurisdiction under section 153C, the material must pertain to the assessee and have a bearing on determination of total income, and a proper satisfaction note is required. On the facts, no such satisfaction note was shown, and the earlier search material could not be used to sustain the proceedings without satisfying the jurisdictional requirement. Since the assessments themselves were held invalid, the merits of the additions did not survive.

Conclusion: The assessments under section 153C were held to be bad in law and were quashed; the additions did not survive, and the assessee succeeded.

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