Section 153C jurisdiction requires seized material to link specifically with the relevant assessment year before notice can stand.

For proceedings under section 153C, the seized material must establish a document-wise or material-wise nexus with the specific assessment year concerned, because that nexus is a jurisdictional fact. A common satisfaction note covering multiple years is insufficient if it does not link the seized jewellery to the year in question or record that the material had a bearing on the assessee's total income for that year. In the absence of such correlation, the statutory condition for invoking section 153C is not satisfied, and the notice is bad in law. The assessment framed under section 153C read with section 143(3) is void ab initio and quashed.

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Issues: Whether the common satisfaction note and the notice issued under section 153C of the Income-tax Act, 1961 were valid when the seized jewellery was not correlated with the relevant assessment year, and whether the assessment framed on that basis could stand.

Analysis: The satisfaction note was recorded commonly for multiple assessment years, but it did not link the seized jewellery to any particular assessment year or record a satisfaction that the material had a bearing on the total income of the assessee for the year in question. The settled position is that for proceedings under section 153C, the seized material must establish a document-wise or material-wise nexus with the assessment year concerned, and this nexus is a jurisdictional fact. In the absence of such correlation, the statutory requirement for invoking section 153C is not met.

Conclusion: The notice under section 153C was bad in law and the assessment framed under section 153C read with section 143(3) was void ab initio and quashed, in favour of the assessee.

Ratio Decidendi: For a valid assumption of jurisdiction under section 153C, the seized material must be shown to have a nexus with the specific assessment year concerned, and absence of such correlation renders the proceedings invalid.

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