Section 153C jurisdiction requires proper satisfaction linking seized material to the assessee; a mere ownership reference is insufficient.

Jurisdiction under section 153C fails unless the recorded satisfaction shows that the seized material pertains to or relates to a person other than the searched person. A mere statement that the material belonged to the assessee does not satisfy the statutory precondition for third-party proceedings. As the Assessing Officer's satisfaction note did not properly establish the necessary nexus with the assessee, the Tribunal held that assumption of jurisdiction was invalid and quashed the assessment framed under section 153C read with section 143(3).

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Issues: Whether the assessment framed under section 153C read with section 143(3) of the Income-tax Act, 1961 was valid when the recorded satisfaction did not properly state that the seized material pertained to or related to the assessee.

Analysis: The Tribunal noted that the search was conducted in the case of another person and that the Assessing Officer recorded satisfaction for initiating proceedings against the assessee as a third party. It held that section 153C requires a proper satisfaction that the seized material pertains to or relates to the person other than the searched person, and that a mere reference that the material belonged to the assessee was insufficient to meet the statutory condition for assuming jurisdiction.

Conclusion: The assessment was held to be unsustainable and was quashed for want of a proper section 153C satisfaction, in favour of the assessee.

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