Section 153C satisfaction must link seized material year-wise; a composite note without bifurcation invalidates jurisdiction.

A consolidated satisfaction note for multiple assessment years under section 153C must identify the seized material and its year-wise nexus with sufficient clarity. Where the note is recorded in composite form without bifurcation of amounts or specific entries linked to each year, the jurisdictional requirement is not met and the resulting reassessment cannot stand. Applying that principle, a mechanically consolidated note was held invalid and the assessment under section 153C was quashed, leaving the remaining grounds academic.

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Issues: Whether a consolidated satisfaction note recorded for multiple assessment years could validly trigger proceedings under section 153C and sustain the consequent assessment.

Analysis: The jurisdiction under section 153C depends on satisfaction that seized material pertains to the non-searched person and has a bearing on the total income of the relevant assessment year or years. The satisfaction must identify the material and its year-wise relevance with sufficient clarity. A note recorded in a composite form for several years, without bifurcation of amounts or identification of year-wise entries, does not show the necessary nexus between the seized material and each assessment year sought to be reopened. On the facts, the Court followed the view that such mechanical consolidation does not satisfy the jurisdictional requirement and distinguished the broader proposition that a common note is not impermissible where it still links the material to the relevant years.

Conclusion: The consolidated satisfaction note was held invalid and the assessment framed under section 153C was quashed; the grounds attacking jurisdiction succeeded and the remaining grounds became academic.

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