Section 153C jurisdiction fails without independent corroborative material linking the seized document to the assessee.

Section 153C jurisdiction requires incriminating material belonging to or relating to the assessee, supported by independent corroboration. A seized sale agreement found in a third party's premises, signed only by the purchaser and not by the vendors, was held insufficient by itself to link the assessee to the document. The satisfaction note also relied solely on that same document and did not identify additional material establishing jurisdiction. Deficiencies in the satisfaction note could not be cured later on appeal. On that basis, initiation under section 153C was invalid and the assessment made under it was unsustainable.

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Issues: Whether proceedings initiated under section 153C of the Income-tax Act, 1961 and the consequent assessment were valid when the seized document was unsigned by the assessee and no independent corroborative material linked the assessee to the document.

Analysis: The seized agreement of sale was found in the premises of a third party and bore only the purchaser's signature, not the signatures of the vendors, including the assessee. In the absence of independent corroborative evidence, the document could not by itself be treated as incriminating material. The satisfaction note also rested entirely on the same document and did not refer to any additional material supporting the jurisdictional assumption under section 153C of the Income-tax Act, 1961. The Tribunal applied the principle that jurisdiction under section 153C can be assumed only where incriminating material belonging to or relating to the assessee exists, and that deficiencies in the satisfaction note cannot be cured by later appellate supplementation.

Conclusion: The initiation of proceedings under section 153C of the Income-tax Act, 1961 was invalid and the assessment framed thereunder was unsustainable; the appeal was allowed.

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