Section 153C satisfaction note must be year-specific and material-linked; a consolidated note vitiates jurisdiction.

Section 153C jurisdiction requires a valid satisfaction note that separately identifies the seized material, the entries relied on, and the specific assessment year to which it pertains. A consolidated note covering multiple years, without year-wise linkage to the assessee, is defective and cannot sustain jurisdiction. Applying earlier coordinate bench decisions, the ITAT Delhi held that the jurisdictional assumption was invalid and quashed the assessment in favour of the assessee.

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Issues: (i) Whether the assumption of jurisdiction under section 153C of the Income-tax Act, 1961 was vitiated by a consolidated and defective satisfaction note recorded for multiple assessment years.

Analysis: The assessment was founded on a single satisfaction note covering several assessment years, without year-wise identification of the material, the entries relied upon, or a clear finding that the seized material pertained to the assessee for the specific year under appeal. The order followed the same reasoning adopted in earlier coordinate bench decisions, which held that section 153C requires a valid satisfaction note with year-wise application and that a consolidated note for multiple years is not sufficient to sustain jurisdiction. Following that view, the Court found the jurisdictional assumption to be invalid.

Conclusion: The jurisdiction under section 153C was invalidly assumed and the assessment was quashed, in favour of the assessee.

Final Conclusion: The appeal succeeded because the search assessment could not survive the jurisdictional defect arising from the defective satisfaction note.

Ratio Decidendi: For invoking section 153C, the satisfaction note must validly and separately connect the seized material to the assessee and to the relevant assessment year; a consolidated or non-specific satisfaction note vitiates the jurisdiction and the resulting assessment.

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