Section 153C jurisdiction fails on an omnibus satisfaction note, and the linked revisionary order cannot survive.

Jurisdiction under section 153C must rest on a year-wise satisfaction note linked to the seized material for the specific assessment year or years affected; a consolidated or omnibus note without bifurcation of the incriminating material cannot validly found jurisdiction. On that basis, the assessment was held void for lack of proper jurisdictional foundation, and the consequential revisionary order under section 263 also failed because it could not survive independently once the underlying assessment was quashed. The relief was therefore granted to the assessee.

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Issues: Whether a consolidated satisfaction note recorded for multiple assessment years vitiated the assumption of jurisdiction under section 153C and rendered the consequent revisionary order under section 263 unsustainable.

Analysis: The assessment under section 153C was founded on a consolidated satisfaction note covering several assessment years, without year-wise bifurcation of the incriminating material or identification of the amounts relatable to each year. Relying on binding precedent, the Tribunal held that jurisdiction under section 153C must be founded on satisfaction linked to the particular assessment year or years impacted by the seized material, and that a mechanical or omnibus exercise cannot confer valid jurisdiction. Since the original assessment itself was found to be void for want of proper jurisdictional basis, the consequential revisionary action under section 263 could not survive independently.

Conclusion: The consolidated satisfaction note was held to be invalid, the assessment under section 153C was quashed, and the order passed under section 263 was set aside, in favour of the assessee.

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