Specific satisfaction note required for section 153C jurisdiction; omnibus year-wise recording without incriminating linkage fails.

Recording of a specific satisfaction note is a condition precedent for invoking section 153C. The note must be based on cogent material, identify the seized material as belonging to or pertaining to the assessee, and link it to the relevant assessment year; a common or omnibus note covering multiple years, without year-wise identification of incriminating material or meaningful analysis of alleged undisclosed income, shows non-application of mind and cannot sustain jurisdiction. For an unabated year, the absence of a valid satisfaction note vitiates the assumption of jurisdiction at the threshold, and the section 153C notice and consequent assessment are liable to be quashed.

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Issues: Whether the assumption of jurisdiction under section 153C was valid when the satisfaction note was common for multiple assessment years and did not identify specific incriminating material relatable to the relevant year.

Analysis: Recording of satisfaction is a condition precedent for invoking section 153C. The satisfaction must be specific, based on cogent material, and must show that the seized material belongs to or pertains to the assessee and has a bearing on the determination of total income for the relevant assessment year. A generalized or omnibus satisfaction note, without year-wise identification of incriminating material and without any meaningful analysis of the alleged undisclosed income, reflects non-application of mind and cannot sustain jurisdiction under section 153C. The assessment year in question being unabated, the absence of a valid, specific satisfaction note vitiates the assumption of jurisdiction at the threshold.

Conclusion: The assumption of jurisdiction under section 153C was invalid, the notice under section 153C and the consequent assessment were quashed, and the Revenue's appeal failed.

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