Section 153C jurisdiction requires a live nexus in the satisfaction note; absence of linked seized material invalidates the assessment.

Invocation of section 153C requires a specific satisfaction note by the Assessing Officer of the searched person linking the seized material to the income of the other person; a general reference to search material is insufficient. Because the satisfaction note did not refer to the material on which the addition was ultimately based, the jurisdictional precondition was not met and the assessment was quashed as without authority of law.

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Issues: Whether the proceedings initiated under section 153C were valid in the absence of a proper satisfaction note linking the seized material to the other person, and whether the consequent assessment was liable to be quashed.

Analysis: The additional grounds challenging jurisdiction were admitted as pure questions of law. For invoking section 153C, the satisfaction recorded by the Assessing Officer of the searched person must specifically refer to the seized material and demonstrate its bearing on the total income of the other person. A mere general reference to search material, without a live link between the seized document and the proposed addition, does not satisfy the statutory precondition. On the facts, the satisfaction note did not refer to the material on which the assessment addition was ultimately founded, and therefore the jurisdictional requirement under section 153C was not met.

Conclusion: The initiation of proceedings under section 153C was invalid and the assessment order was quashed.

Ratio Decidendi: Invocation of section 153C requires a specific satisfaction note based on seized material showing a live nexus with the income of the other person; in the absence of such jurisdictional satisfaction, the assessment is without authority of law.

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