Section 153C jurisdiction fails without recorded satisfaction linking seized material to total income determination.

Jurisdiction under section 153C of the Income-tax Act was invalid where the satisfaction note did not record the mandatory linkage between the seized material and the determination of the assessee's total income for the relevant years. The note had to show that the documents belonged to the assessee and had a bearing on total income; absence of that recorded precondition meant the statutory basis for proceedings was not satisfied. The assessment was therefore quashed, and the remaining grounds were left open.

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Issues: Whether the assumption of jurisdiction under section 153C of the Income-tax Act, 1961 was valid in the absence of a recorded satisfaction that the seized material had a bearing on the determination of the assessee's total income for the relevant years.

Analysis: The assessment was founded on material found during a search under section 132 of the Income-tax Act, 1961 and a satisfaction note recorded by the authorities. The note, however, did not record the statutory precondition that the seized documents belonging to the assessee had a bearing on the determination of total income. Recording of that linkage was treated as a mandatory jurisdictional requirement for invoking section 153C.

Conclusion: The assumption of jurisdiction under section 153C was held to be invalid and the assessment was quashed. The remaining grounds were left open.

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