2026 (4) TMI 200 - SCH - Income Tax

Assessment under section 153C needs year-specific incriminating material and jurisdictional satisfaction before notices can stand.

Assessment under section 153C requires assessment year-wise incriminating material and corresponding jurisdictional satisfaction before initiation. Where ... Validity of assessment u/s 153C - Assessment year-wise nexus of incriminating material u/s 153C - Jurisdictional satisfaction for initiation of proceedings u/s 153C - satisfaction note identified incriminating material only for different assessment years - HC held the impugned notices u/s 153C and all consequential proceedings, holding that in the absence of assessment year-specific incriminating material and corresponding jurisdictional satisfaction, such notices could not be sustained. HELD THAT:- Special Leave Petitions were dismissed as no ground for interference with the impugned orders was found. Outcome: Special Leave Petitions dismissed [No detailed order].