https://www.taxtmi.com/caselaws?id=457222 Section 153C jurisdiction turned on whether incriminating material found in a search related to, or was likely to impact, the total income of each year sought to be covered. Applying HC precedent, the AO must record satisfaction that the seized material has a bearing on specific AYs; absent such year-wise nexus, Section 153C cannot be invoked for those years. As the satisfaction note for the non-searched person referred only to material pertaining to AY 2019-20, initiation for AYs 2014-15 to 2018-19 and 2020-21 lacked the statutory foundation and was quashed. The challenge to whether the material for AY 2019-20 was incriminating involved disputed facts and was left to the assessment; proceedings for AY 2019-20 were not interfered with. en-us Fri, 24 May 2024 00:00:00 +0530 Tue, 23 Dec 2025 12:15:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=457222 Section 153C jurisdiction turned on whether incriminating material found in a search related to, or was likely to impact, the total income of each year sought to be covered. Applying HC precedent, the AO must record satisfaction that the seized material has a bearing on specific AYs; absent such year-wise nexus, Section 153C cannot be invoked for those years. As the satisfaction note for the non-searched person referred only to material pertaining to AY 2019-20, initiation for AYs 2014-15 to 2018-19 and 2020-21 lacked the statutory foundation and was quashed. The challenge to whether the material for AY 2019-20 was incriminating involved disputed facts and was left to the assessment; proceedings for AY 2019-20 were not interfered with. Case-Laws Income Tax Fri, 24 May 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=457222