Section 153C jurisdiction requires year-wise satisfaction; a consolidated note for multiple years is legally invalid.

For proceedings under section 153C of the Income-tax Act, satisfaction must be recorded separately for each assessment year because jurisdiction is assessment-year specific. A consolidated satisfaction note covering multiple years does not satisfy that requirement and is fatal to the assumption of jurisdiction. On that basis, the Tribunal treated the combined satisfaction exercise as contrary to law and held that the resulting section 153C proceedings and consequential assessment could not stand.

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Issues: Whether a consolidated satisfaction note recorded under section 153C of the Income-tax Act, 1961 for multiple assessment years vitiates the proceedings and the consequential assessment.

Analysis: The assessee challenged the validity of the proceedings on the ground that the Assessing Officer of the searched person and the Assessing Officer of the assessee had recorded combined satisfaction notes for several assessment years instead of year-wise satisfaction. The Tribunal noted that the satisfaction notes covered multiple years in one composite exercise and relied on the view that satisfaction under section 153C must be recorded separately for each assessment year because jurisdiction under that provision is assessment-year specific. On that basis, the Tribunal held that a consolidated satisfaction note is not in accordance with law and affects the very assumption of jurisdiction for proceedings under section 153C.

Conclusion: The consolidated satisfaction note invalidated the section 153C proceedings, and the assessee succeeded on the legal challenge.

Ratio Decidendi: For proceedings under section 153C of the Income-tax Act, 1961, satisfaction must be recorded separately for each assessment year, and a consolidated satisfaction note for multiple years is fatal to the assumption of jurisdiction and the resulting assessment.

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