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Issues: Whether a consolidated satisfaction note for multiple assessment years, without year-wise bifurcation of incriminating material, validly triggers jurisdiction under section 153C of the Income-tax Act, 1961 and supports the consequential assessment.
Analysis: The assessment was founded on a satisfaction note recorded in a composite form for several assessment years, but it did not identify year-wise incriminating material or explain how the seized material related to each year. The decision relies on the principle that section 153C requires satisfaction that the material seized is likely to have a bearing on the total income of the relevant assessment year or years, and that the jurisdiction cannot be assumed mechanically for an entire block of years merely because some material was found in a search. Applying the later binding view favouring year-linked satisfaction, the consolidated note was treated as insufficient to sustain jurisdiction.
Conclusion: The consolidated satisfaction note was held invalid for assumption of jurisdiction under section 153C, and the assessment was quashed in favour of the assessee.
Ratio Decidendi: Jurisdiction under section 153C can be assumed only on the basis of satisfaction linked to incriminating material having a bearing on the total income of the particular assessment year concerned, and a composite note for multiple years without year-wise nexus is not sufficient.
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