https://www.taxtmi.com/caselaws?id=793028 Recording of satisfaction is a jurisdictional precondition for invoking section 153C, and it must be specific, year-wise and supported by cogent seized material showing that the material belongs to or pertains to the assessee and bears on total income. A common, vague or mechanical satisfaction note for multiple years, without identification of incriminating material or nexus with undisclosed income, reflects non-application of mind and is insufficient. On the facts discussed, a third-party ledger without independent corroboration or meaningful enquiry did not establish the required nexus. For an unabated assessment, the absence of a valid satisfaction note made the assumption of jurisdiction under section 153C unsustainable, and the notice and consequential assessment order were quashed. en-us Wed, 13 May 2026 00:00:00 +0530 Mon, 08 Jun 2026 08:52:40 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=793028 Recording of satisfaction is a jurisdictional precondition for invoking section 153C, and it must be specific, year-wise and supported by cogent seized material showing that the material belongs to or pertains to the assessee and bears on total income. A common, vague or mechanical satisfaction note for multiple years, without identification of incriminating material or nexus with undisclosed income, reflects non-application of mind and is insufficient. On the facts discussed, a third-party ledger without independent corroboration or meaningful enquiry did not establish the required nexus. For an unabated assessment, the absence of a valid satisfaction note made the assumption of jurisdiction under section 153C unsustainable, and the notice and consequential assessment order were quashed. Case-Laws Income Tax Wed, 13 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=793028