https://www.taxtmi.com/caselaws?id=793703 For valid initiation under section 153C, the satisfaction note must expressly record that the seized material has a bearing on determination of the assessee's total income; absent that jurisdictional satisfaction, the notice and consequent assessment are unsustainable. The ITAT found the recorded note referred to the search, seized material and year-wise transactions, but omitted this essential statutory finding, so the foundation for section 153C proceedings was defective. The notice and assessment order were quashed, and the remaining grounds were not adjudicated. en-us Mon, 15 Jun 2026 00:00:00 +0530 Mon, 22 Jun 2026 08:39:16 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=793703 For valid initiation under section 153C, the satisfaction note must expressly record that the seized material has a bearing on determination of the assessee's total income; absent that jurisdictional satisfaction, the notice and consequent assessment are unsustainable. The ITAT found the recorded note referred to the search, seized material and year-wise transactions, but omitted this essential statutory finding, so the foundation for section 153C proceedings was defective. The notice and assessment order were quashed, and the remaining grounds were not adjudicated. Case-Laws Income Tax Mon, 15 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=793703