Section 153C jurisdiction depends on independent satisfaction and the sunset bar can invalidate proceedings if cutoff timing is crossed.

Invocation of section 153C of the Income-tax Act requires the Assessing Officer to record an independent jurisdictional satisfaction that seized books, documents, assets or information have a bearing on the other person's total income; a mere forwarding letter or list, without examining and linking the material to income, is insufficient. It also explains that the first proviso to section 153C(1) fixes the relevant date as the date the seized material is received by the other person's Assessing Officer, and if that date falls after 01.04.2021, the sunset bar in section 153C(3) applies. On that footing, proceedings are without jurisdiction and assessment orders are set aside.

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Issues: (i) Whether the satisfaction recorded for invoking section 153C of the Income-tax Act, 1961 was valid in law. (ii) Whether the proceedings under section 153C were barred by the sunset clause in section 153C(3) of the Income-tax Act, 1961.

Issue (i): Whether the satisfaction recorded for invoking section 153C of the Income-tax Act, 1961 was valid in law.

Analysis: For invoking section 153C, the Assessing Officer of the other person must record a jurisdictional satisfaction that the seized books of account, documents, assets, or information contained therein have a bearing on the determination of the total income of such other person. A mere reproduction of the forwarding letter or a summary list, without independent examination of the seized material and without linking the material to the assessee's income, does not satisfy the statutory requirement.

Conclusion: The satisfaction recorded was held to be invalid, and the assumption of jurisdiction under section 153C was held not to be legally sustainable.

Issue (ii): Whether the proceedings under section 153C were barred by the sunset clause in section 153C(3) of the Income-tax Act, 1961.

Analysis: The first proviso to section 153C(1) deems the relevant date for the other person to be the date on which the seized material is received by that person's Assessing Officer. Since the material was received after 01.04.2021, the statutory bar in section 153C(3) applied. On that footing, the provision could not be invoked and the proceedings were without jurisdiction.

Conclusion: The proceedings were held to be barred by section 153C(3) and the assessment was quashed.

Final Conclusion: The assessment orders passed under section 153C were set aside on jurisdictional grounds, and the substantive additions were left unadjudicated.

Ratio Decidendi: A valid invocation of section 153C requires independent jurisdictional satisfaction based on seized material having a bearing on the other person's total income, and the provision cannot be invoked where the deemed date of receipt of such material falls after the statutory cutoff in section 153C(3).

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