https://www.taxtmi.com/caselaws?id=469807 For valid initiation of proceedings under section 153C of the Income-tax Act, the satisfaction note must clearly identify the seized material belonging to the assessee and link it to the correct assessment year. A consolidated note that does not record year-wise, specific satisfaction based solely on the seized material handed over by the searched person's Assessing Officer is defective. On the facts stated, the jurisdictional prerequisite was not met, so the assumption of jurisdiction under section 153C was invalid and the consequential assessment proceedings and additions were quashed in favour of the assessee. en-us Fri, 06 Feb 2026 00:00:00 +0530 Sat, 04 Jul 2026 10:32:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=469807 For valid initiation of proceedings under section 153C of the Income-tax Act, the satisfaction note must clearly identify the seized material belonging to the assessee and link it to the correct assessment year. A consolidated note that does not record year-wise, specific satisfaction based solely on the seized material handed over by the searched person's Assessing Officer is defective. On the facts stated, the jurisdictional prerequisite was not met, so the assumption of jurisdiction under section 153C was invalid and the consequential assessment proceedings and additions were quashed in favour of the assessee. Case-Laws Income Tax Fri, 06 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=469807