Year-wise satisfaction under section 153C is jurisdictional; a consolidated note cannot sustain the assessment.

A consolidated satisfaction note under section 153C, recorded for multiple assessment years rather than year-wise, was held insufficient to meet the jurisdictional requirement for initiation of proceedings. On that footing, the assessment framed under section 143(3) read with section 153C for the year under appeal could not be sustained and was quashed. The remaining grounds on merits were left open and not adjudicated because the foundational jurisdictional defect was ative.

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Issues: Whether a consolidated satisfaction note recorded under section 153C for multiple assessment years was valid, and whether the assessment framed under section 143(3) read with section 153C for the relevant year was liable to be quashed.

Analysis: The Tribunal accepted the assessee's challenge that the satisfaction note was not year-wise and was recorded in a consolidated form for assessment years 2014-15 to 2020-21. It followed its coordinate Bench decision and held that such a composite satisfaction note, in the facts of the case, failed to satisfy the jurisdictional requirement for initiation of proceedings under section 153C. Once the foundational jurisdictional defect was found, the assessment made under section 143(3) read with section 153C could not survive. As the assessment was set aside on the legal issue, the remaining grounds on merits were not adjudicated and were left open.

Conclusion: The consolidated satisfaction note was held invalid, and the assessment for the year under appeal was quashed. The issue was decided in favour of the assessee.

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