https://www.taxtmi.com/caselaws?id=467874 Section 153C proceedings require the Assessing Officer to record valid satisfaction that seized material pertains to the other person and has a bearing on that person's total income. The note here did not record that statutory linkage, so the jurisdictional condition was not met and initiation could not be sustained. The text also applies the post-amendment cut-off: where the relevant date for initiation is the receipt of seized material, and that date fell after 01.04.2021, section 153C was barred for searches covered by the exclusion. On both grounds, the assumed jurisdiction failed and the assessments were quashed. en-us Tue, 27 Jan 2026 00:00:00 +0530 Mon, 11 May 2026 11:59:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=467874 Section 153C proceedings require the Assessing Officer to record valid satisfaction that seized material pertains to the other person and has a bearing on that person's total income. The note here did not record that statutory linkage, so the jurisdictional condition was not met and initiation could not be sustained. The text also applies the post-amendment cut-off: where the relevant date for initiation is the receipt of seized material, and that date fell after 01.04.2021, section 153C was barred for searches covered by the exclusion. On both grounds, the assumed jurisdiction failed and the assessments were quashed. Case-Laws Income Tax Tue, 27 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=467874