Valid recorded satisfaction is essential for section 153C jurisdiction; absence of such note makes the assessment unsustainable.

Section 153C could not be validly invoked against a person other than the searched person unless the record showed a valid recorded satisfaction note establishing jurisdiction. As no satisfaction note was produced and the Assessing Officer admitted that no copy was available in the office records, the jurisdictional foundation failed. The assessment was therefore quashed in favour of the assessee, and the challenge to approval under section 153D became academic.

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Issues: Whether the assessment framed under section 153C was liable to be quashed for want of a valid recorded satisfaction note, thereby rendering the assumption of jurisdiction invalid.

Analysis: The assessee was not the person searched, and the initiation of proceedings under section 153C depended upon the prior recording of satisfaction. The record produced did not contain a satisfaction note, and the Assessing Officer also admitted that no copy of such note was available in the office records. In these circumstances, the essential jurisdictional requirement for invoking section 153C was not established. Once the foundational assumption of jurisdiction failed, the challenge relating to approval under section 153D did not require adjudication and became academic.

Conclusion: The assessment under section 153C was invalid for want of proof of a valid recorded satisfaction, and the assessment was quashed in favour of the assessee.

Ratio Decidendi: Invocation of section 153C is unsustainable unless the existence of a valid recorded satisfaction establishing jurisdiction is shown from the record.

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