Jurisdictional satisfaction under 153C requires year-wise linkage of seized material; aggregated notes invalidate reopening and assessments.

Jurisdictional satisfaction for reopening must state that material seized from a searched person is likely to affect determination of income for each specific assessment year; an aggregated satisfaction note covering multiple years without year wise identification of incriminating material fails to evidence the requisite opinion and therefore cannot sustain assumption of jurisdiction for reopening. The operative effect is that assessments framed on the basis of such an invalid consolidated satisfaction note lack a jurisdictional foundation and are vulnerable to being quashed.

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Issues: Whether a consolidated satisfaction note recorded for multiple assessment years, without year-wise identification of incriminating material, validly permits initiation of proceedings under Section 153C of the Income-tax Act, 1961 and consequent framing of assessments for the years under challenge.

Analysis: The statutory scheme requires that action under Section 153C proceed upon satisfaction that material received from a searched person is likely to have a bearing on the determination of total income of the other person for the specific assessment year(s) sought to be reopened. A satisfaction note that aggregates multiple years without identifying year-wise incriminating material fails to evidence the requisite formation of opinion that the seized material is likely to impact a particular assessment year. Where the satisfaction note does not identify amounts or material by assessment year, the foundational requirement for assuming jurisdiction under Section 153C is not met. The consequence of an invalid satisfaction note is that abatement and re-opening under Section 153C cannot be sustained and the resultant assessment orders lack jurisdictional basis.

Conclusion: The consolidated satisfaction note recorded for multiple assessment years without year-wise identification of incriminating material is invalid and fatal to the assumption of jurisdiction under Section 153C of the Income-tax Act, 1961; assessments framed on that basis are quashed.

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