Section 153C jurisdiction fails without the searched person's satisfaction note, leading to quashing of assessments.

Recording of satisfaction by the Assessing Officer of the searched person is a prerequisite for valid jurisdiction under section 153C before material is transmitted to the Assessing Officer of the other person. Where that satisfaction note cannot be produced, the jurisdictional foundation for the assessment fails. On these facts, the ITAT held the assessments under section 153C to be bad in law and without jurisdiction, and quashed the assessment orders. The other grounds were left open after the jurisdictional objection succeeded.

---

---

Issues: Whether the assessments under section 153C of the Income-tax Act, 1961 were valid when the Assessing Officer did not have the satisfaction note recorded by the Assessing Officer of the searched person.

Analysis: The recorded material showed that the Assessing Officer could not produce the satisfaction note of the searched person. For a valid assumption of jurisdiction under section 153C, recording of satisfaction by the Assessing Officer of the searched person is a prerequisite before transmitting the material to the Assessing Officer having jurisdiction over the other person. In the absence of such satisfaction note, the jurisdictional foundation for completing the assessment under section 153C fails. The same reasoning applied to both assessment years, and the other grounds were left open after the jurisdictional objection succeeded.

Conclusion: The assessments under section 153C were held to be bad in law and without jurisdiction, and the assessment orders were quashed.

---