Section 153C jurisdiction requires seized material linking the assessee and the relevant year; notice was invalid without that nexus.

Section 153C jurisdiction depends on seized material that belongs to, pertains to, or relates to the other person and has a direct nexus with the relevant assessment year. Here, the seized documents cited in the satisfaction note were found to relate to other entities, not the assessee, and the record did not establish that they belonged to the assessee or bore on income for the year in issue. Without these jurisdictional facts, the statutory precondition for issuing notice under section 153C was not met, and the notice was therefore invalid. The assessment founded on that notice could not be sustained.

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Issues: Whether notice issued under section 153C of the Income-tax Act, 1961 was valid in the absence of seized incriminating material belonging to the assessee and bearing on the relevant assessment year.

Analysis: The Revenue's challenge failed because the seized documents referred to in the satisfaction note were found to relate to other entities and not to the assessee. The record did not establish that the material belonged to the assessee or that it had a nexus with the determination of income for the relevant assessment year. The statutory precondition for invoking section 153C is the existence of seized material that belongs to, pertains to, or relates to the other person, together with a valid satisfaction recording such nexus. The absence of such jurisdictional facts rendered the notice invalid. The principle applied was that incriminating seized material and the relevant assessment year must have a direct correlation for assumption of jurisdiction under section 153C.

Conclusion: The notice under section 153C was held to be invalid and the assessment based on it could not be sustained.

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