Year-specific incriminating material is essential for Section 153C jurisdiction; consequential notices fall if the foundation fails.

Jurisdiction under Section 153C of the Income-tax Act depends on seized or incriminating material relating to the specific assessment year covered by the satisfaction note. Where the note referred only to different financial years and corresponding assessment years, a notice issued for Assessment Year 2016-17 could not be sustained. As the foundational Section 153C notice lacked jurisdiction, the consequential notices under Sections 143(2) and 142(1) also failed and were set aside. The operative principle is that absence of year-specific incriminating material defeats Section 153C proceedings entirely.

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Issues: (i) Whether a notice under Section 153C of the Income-tax Act, 1961 can be issued for an assessment year not covered by the satisfaction note and, if not, whether the consequential notices under Sections 143(2) and 142(1) survive.

Analysis: The jurisdiction under Section 153C is triggered only when the seized or incriminating material belongs to or relates to the relevant assessment years. The satisfaction note in the present case referred to financial years and corresponding assessment years different from Assessment Year 2016-17, yet the impugned notice was issued for Assessment Year 2016-17. The Court followed the binding principle that the presence of incriminating material for the specific assessment year is a jurisdictional requirement and that, in its absence, action under Section 153C cannot be sustained. Since the foundational notice failed, the notices issued consequentially under Sections 143(2) and 142(1) also could not stand.

Conclusion: The impugned notice under Section 153C for Assessment Year 2016-17 was quashed, and the consequential notices under Sections 143(2) and 142(1) were also set aside, in favour of the assessee.

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