Section 153C jurisdiction requires a satisfaction note linking seized material to total income; absent that link, assessments fail.

For valid assumption of jurisdiction under section 153C, the satisfaction note must expressly record that the seized material has a bearing on determination of the assessee's total income. As this essential linkage was not recorded, the statutory basis for the proceedings was deficient. The assessments were therefore treated as invalid and non est, and the jurisdictional challenge succeeded. The Revenue's appeals were dismissed and the cross objections were allowed.

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Issues: (i) Whether the section 153C assessments for the relevant assessment years were valid when the satisfaction note did not record that the seized material had a bearing on ination of the assessee's total income.

Analysis: The search action was carried out under section 132 of the Income-tax Act, 1961, and the impugned proceedings were initiated after the recorded satisfaction of the searched party's Assessing Officer and the assessee's jurisdictional Assessing Officer. The decisive requirement was whether the satisfaction note clearly stated that the seized material had a bearing on determination of the assessee's total income. As that element was not recorded, the statutory basis for invoking section 153C was held to be deficient.

Conclusion: The section 153C assessments were held to be invalid and non-est, and the assessee succeeded on this issue.

Final Conclusion: The common order resulted in the assessee succeeding on the jurisdictional challenge to the assessments, with the Revenue's appeals dismissed and the cross objections allowed.

Ratio Decidendi: For a valid assumption of jurisdiction under section 153C, the satisfaction note must expressly show that the seized material has a bearing on determination of the assessee's total income.

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