Section 153C jurisdiction fails where the satisfaction note is not year-specific or clearly linked to seized material.

For valid initiation of proceedings under section 153C of the Income-tax Act, the satisfaction note must clearly identify the seized material belonging to the assessee and link it to the correct assessment year. A consolidated note that does not record year-wise, specific satisfaction based solely on the seized material handed over by the searched person's Assessing Officer is defective. On the facts stated, the jurisdictional prerequisite was not met, so the assumption of jurisdiction under section 153C was invalid and the consequential assessment proceedings and additions were quashed in favour of the assessee.

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Issues: Whether jurisdiction under section 153C of the Income-tax Act, 1961 was validly assumed on the basis of the satisfaction note recorded in respect of the seized material.

Analysis: The record showed that the satisfaction note did not specify, with clarity, which seized entry belonged to the assessee or to which assessment year it related. The note was also prepared in a consolidated form and was not confined to a clear, year-specific satisfaction based solely on the seized material handed over by the searched person's Assessing Officer. In these circumstances, the jurisdictional prerequisite for proceedings under section 153C was not satisfied.

Conclusion: The assumption of jurisdiction under section 153C was invalid, and the consequential assessment proceedings and additions were quashed in favour of the assessee.

Ratio Decidendi: For valid initiation under section 153C, the satisfaction note must be specific, year-wise, and must clearly connect the seized material with the assessee; a defective or consolidated satisfaction note vitiates the resulting assessment.

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