https://www.taxtmi.com/caselaws?id=785174 Section 153C proceedings require a jurisdictional AO's satisfaction note before notice is issued, and the search or requisition material must have a real bearing on the computation of income for the relevant assessment year or years. The commentary explains that reopening or abatement should not be treated as mechanically extending to the entire block of years merely because incriminating material exists; instead, the material must be linked to the assessment years likely to be impacted. It further states that abatement of the six assessment years or the relevant year follows the formation of that opinion and satisfaction, not the other way around. en-us Fri, 16 Jan 2026 00:00:00 +0530 Mon, 19 Jan 2026 07:36:44 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=785174 Section 153C proceedings require a jurisdictional AO's satisfaction note before notice is issued, and the search or requisition material must have a real bearing on the computation of income for the relevant assessment year or years. The commentary explains that reopening or abatement should not be treated as mechanically extending to the entire block of years merely because incriminating material exists; instead, the material must be linked to the assessment years likely to be impacted. It further states that abatement of the six assessment years or the relevant year follows the formation of that opinion and satisfaction, not the other way around. Case-Laws Income Tax Fri, 16 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=785174