Section 153C jurisdiction fails where the satisfaction note lacks document-wise and year-wise correlation to seized material.

Section 153C jurisdiction requires a satisfaction note that specifically identifies the seized material and correlates it document-wise and year-wise to the assessee and the relevant assessment years. A consolidated note that does not show which documents belong to or pertain to the assessee, or how each item is relevant to each year, is insufficient to confer valid jurisdiction. On that reasoning, the assumption of jurisdiction under section 153C was held invalid, and the assessee succeeded on the jurisdictional challenge.

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Issues: Validity of assumption of jurisdiction under section 153C of the Income-tax Act, 1961 on the basis of the recorded satisfaction note, particularly whether the note was sufficiently document-wise and year-wise correlated to the assessee and the relevant assessment years.

Analysis: The search proceedings led to recording of satisfaction for initiating proceedings under section 153C read with section 153A. The recorded satisfaction was examined and found to be in a consolidated form, without identifying which seized documents specifically belonged to or pertained to the assessee, without correlating those materials year-wise to the assessment years under consideration, and without showing the quantum or relevance of the seized material for each year. In the absence of such specific linkage, the satisfaction note did not meet the statutory requirement for valid assumption of jurisdiction under section 153C. The reasoning followed the settled principle that the jurisdictional satisfaction must be based on identifiable incriminating material with proper document-wise and year-wise correlation.

Conclusion: The assumption of jurisdiction under section 153C was not valid, and the assessee succeeded on this issue.

Final Conclusion: The jurisdictional challenge was accepted, the connected assessment years were treated on the same footing, and the appeals were disposed of partly in favour of the assessee.

Ratio Decidendi: For valid invocation of section 153C, the satisfaction note must specifically identify the seized material and correlate it document-wise and year-wise to the assessee and the relevant assessment year; a vague consolidated satisfaction note is insufficient to confer jurisdiction.

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