Year-specific satisfaction is essential for 153C jurisdiction; a consolidated note without linkage invalidates the assessments.

Jurisdiction under section 153C requires satisfaction based on seized material linked to the relevant assessment year or years and bearing on total income for those years. A consolidated satisfaction note that does not separately identify year-wise material or bifurcate amounts relatable to each year fails this statutory requirement. Because the note was not year-specific and did not establish the necessary linkage to individual assessment years, the assumption of jurisdiction was unsustainable and the consequential assessments were quashed in favour of the assessee.

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Issues: Whether a consolidated satisfaction note recorded for multiple assessment years under section 153C of the Income-tax Act, 1961 validly sustained the assumption of jurisdiction and the consequential assessments.

Analysis: The satisfaction note was common for all the assessment years and did not separately identify year-wise material or bifurcate the amounts relatable to each assessment year. The decision turned on the requirement that the jurisdictional satisfaction under section 153C must be founded on material having a bearing on the determination of total income for the relevant year or years. The view taken was that where the material and reasons are not year-specific and the note is recorded in a consolidated manner without linking the seized material to individual assessment years, the statutory condition for invoking section 153C is not met.

Conclusion: The consolidated satisfaction note was held invalid, the jurisdiction assumed under section 153C was unsustainable, and the assessments were quashed in favour of the assessee.

Ratio Decidendi: For invoking section 153C, the Assessing Officer must record satisfaction linking the seized material to the relevant assessment year or years so that the material is shown to have a bearing on total income for those years; a consolidated note unsupported by year-wise linkage cannot validly confer jurisdiction.

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