https://www.taxtmi.com/caselaws?id=788971 ITAT Bangalore held that proceedings under section 153C require year-wise satisfaction recorded separately for each assessment year on the basis of seized material attributable to that year. A consolidated satisfaction note covering assessment years 2015-16 to 2020-21, where the search yielded only one agreement and no other incriminating material linking distinct years, was insufficient. The Tribunal applied the binding jurisdictional view that a composite satisfaction note for multiple years vitiates the proceedings and distinguished the Revenue's contrary reliance because there was no year-specific seized material covering all years. The notices and consequential assessments under section 153C were therefore unsustainable. en-us Tue, 10 Mar 2026 00:00:00 +0530 Wed, 01 Apr 2026 07:51:07 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=788971 ITAT Bangalore held that proceedings under section 153C require year-wise satisfaction recorded separately for each assessment year on the basis of seized material attributable to that year. A consolidated satisfaction note covering assessment years 2015-16 to 2020-21, where the search yielded only one agreement and no other incriminating material linking distinct years, was insufficient. The Tribunal applied the binding jurisdictional view that a composite satisfaction note for multiple years vitiates the proceedings and distinguished the Revenue's contrary reliance because there was no year-specific seized material covering all years. The notices and consequential assessments under section 153C were therefore unsustainable. Case-Laws Income Tax Tue, 10 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=788971