Valid satisfaction for section 153C proceedings is mandatory; assessments fail where seized material is not properly linked to the assessee.

A valid satisfaction note linking specific seized material to the assessee is a mandatory jurisdictional prerequisite for proceedings under section 153C of the Income-tax Act, 1961. Where the note does not clearly identify the seized material as belonging to, pertaining to, or relating to the assessee, the statutory condition for assuming jurisdiction is not met. On that basis, the assessments framed under section 153C were held unsustainable and were quashed, and the appeals were allowed.

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Issues: Whether the assessments framed under section 153C of the Income-tax Act, 1961 were valid in the absence of a proper satisfaction recording that the seized material belonged to, pertained to, or related to the assessee.

Analysis: The satisfaction note did not clearly identify the specific seized material as belonging to, pertaining to, or relating to the assessee, which is a jurisdictional requirement for initiating proceedings under section 153C. In the absence of such valid satisfaction, the precondition for assuming jurisdiction under section 153C was not met.

Conclusion: The assessments under section 153C were held unsustainable and were quashed, with the appeals allowed.

Ratio Decidendi: A valid satisfaction linking specific seized material to the assessee is a mandatory jurisdictional prerequisite for initiating proceedings under section 153C of the Income-tax Act, 1961.

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