Year-specific satisfaction under Section 153C is essential; a consolidated note cannot sustain jurisdiction for multiple years.

Section 153C requires year-specific satisfaction that seized material is likely to affect determination of total income for the relevant assessment year. A consolidated satisfaction note covering multiple years, without independent year-wise linkage, was treated as an impermissible mechanical invocation of jurisdiction. On that basis, the assumption of jurisdiction under section 153C failed, and the assessments for the years in question were quashed.

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Issues: Whether the recording of a consolidated satisfaction note for multiple assessment years vitiated the assumption of jurisdiction under section 153C of the Income-tax Act, 1961 and the consequential assessments for the relevant years.

Analysis: The seized material was relied upon to initiate proceedings under section 153C on the footing that it related to the assessee and had a bearing on total income. The Tribunal noted that the satisfaction note for the non-searched person covered several assessment years in one go, without recording independent year-wise satisfaction. Placing reliance on the view that section 153C requires satisfaction that the material is likely to affect the determination of total income for the specific assessment year or years concerned, the Tribunal held that a mechanical, omnibus invocation of jurisdiction for multiple years is impermissible where the record does not show year-specific linkage.

Conclusion: The consolidated satisfaction note was held to be fatal to the assumption of jurisdiction under section 153C for the assessment years in question, and the assessments were quashed.

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