Section 153C jurisdiction fails where a consolidated satisfaction note is used without year-wise independent satisfaction.

Assessment under Section 153C was invalid where jurisdiction was assumed on the basis of a single consolidated satisfaction note covering multiple assessment years without year-wise independent satisfaction. Applying its earlier view and the prevailing requirement that satisfaction must relate to the relevant assessment year and justify action for that year, the Tribunal treated the consolidated note as defective and fatal to jurisdiction. The assessment framed under Section 153C was therefore quashed in favour of the assessee.

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Issues: Whether assessment proceedings initiated under Section 153C on the basis of a consolidated satisfaction note recorded for multiple assessment years, without year-wise independent satisfaction, were valid.

Analysis: The assessment was founded on a single consolidated satisfaction note covering several assessment years. The Tribunal followed its earlier decision in the assessee's own case and applied the then prevailing judicial view that, for invoking Section 153C, the satisfaction must be recorded with reference to the relevant assessment year and the material must justify action for that year. A consolidated note which does not separately identify the year-wise basis for initiation was treated as defective and fatal to the assumption of jurisdiction. On that basis, the assessment framed under Section 153C could not be sustained.

Conclusion: The consolidated satisfaction note was held invalid and the assessment under Section 153C was quashed, in favour of the assessee.

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