Section 153C jurisdiction fails without a valid deemed search date and assessee-specific material for relevant assessment years.
Section 153C jurisdiction over a person other than the searched person depends on the deemed search date, determined by recording satisfaction or receiving records. Where satisfaction was recorded in the deemed search year 2022-23, section 153C(3) did not permit proceedings for that year; any reassessment recourse lay under section 147. Jurisdiction also requires a satisfaction note identifying material specifically relating to that person and linking it to alleged escaped income for the relevant assessment years. General references to electronic evidence, or a ledger already contained in regular books without that linkage, cannot support consolidated satisfaction for multiple years. Failure of both requirements renders the assessments legally unsustainable.
Issues: (i) Whether assessments under section 153C could be initiated where the deemed search year, determined from the date of recording satisfaction in the case of a person other than the searched person, fell after 1 April 2021; (ii) Whether a consolidated satisfaction note without identification of adverse material specifically relating to the assessee and the relevant assessment years validly conferred jurisdiction under section 153C.
Issue (i): Whether assessments under section 153C could be initiated where the deemed search year, determined from the date of recording satisfaction in the case of a person other than the searched person, fell after 1 April 2021.
Analysis: For a person other than the searched person, the date of recording satisfaction or receipt of records by that person's Assessing Officer is the deemed date of search. As satisfaction was recorded on 5 August 2022, the deemed search year was 2022-23. Under the statutory framework of section 153C(3), proceedings under section 153C were unavailable for that deemed search year; recourse, if any, lay under section 147.
Conclusion: The assumption of jurisdiction under section 153C was invalid, in favour of the assessee.
Issue (ii): Whether a consolidated satisfaction note without identification of adverse material specifically relating to the assessee and the relevant assessment years validly conferred jurisdiction under section 153C.
Analysis: The satisfaction note merely referred generally to digital devices and electronic evidence and did not identify adverse material concerning the assessee or establish its nexus with escapement of income for the assessment years involved. A ledger already forming part of the regular books could not, without such identified linkage, support a consolidated satisfaction for the block of years.
Conclusion: The consolidated satisfaction note was legally insufficient to confer jurisdiction under section 153C, in favour of the assessee.
Final Conclusion: Both jurisdictional foundations for the assessments failed, rendering the assessments legally unsustainable.
Ratio Decidendi: Jurisdiction under section 153C for a person other than the searched person requires determination of the deemed search date from the relevant satisfaction and a satisfaction note disclosing material specifically linked to that person and to the alleged escaped income.