https://www.taxtmi.com/caselaws?id=793699 Recording of a specific satisfaction note is a condition precedent for invoking section 153C. The note must be based on cogent material, identify the seized material as belonging to or pertaining to the assessee, and link it to the relevant assessment year; a common or omnibus note covering multiple years, without year-wise identification of incriminating material or meaningful analysis of alleged undisclosed income, shows non-application of mind and cannot sustain jurisdiction. For an unabated year, the absence of a valid satisfaction note vitiates the assumption of jurisdiction at the threshold, and the section 153C notice and consequent assessment are liable to be quashed. en-us Thu, 04 Jun 2026 00:00:00 +0530 Mon, 22 Jun 2026 08:39:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=793699 Recording of a specific satisfaction note is a condition precedent for invoking section 153C. The note must be based on cogent material, identify the seized material as belonging to or pertaining to the assessee, and link it to the relevant assessment year; a common or omnibus note covering multiple years, without year-wise identification of incriminating material or meaningful analysis of alleged undisclosed income, shows non-application of mind and cannot sustain jurisdiction. For an unabated year, the absence of a valid satisfaction note vitiates the assumption of jurisdiction at the threshold, and the section 153C notice and consequent assessment are liable to be quashed. Case-Laws Income Tax Thu, 04 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=793699