https://www.taxtmi.com/caselaws?id=799420 Section 153C jurisdiction over a person other than the searched person depends on the deemed search date, determined by recording satisfaction or receiving records. Where satisfaction was recorded in the deemed search year 2022-23, section 153C(3) did not permit proceedings for that year; any reassessment recourse lay under section 147. Jurisdiction also requires a satisfaction note identifying material specifically relating to that person and linking it to alleged escaped income for the relevant assessment years. General references to electronic evidence, or a ledger already contained in regular books without that linkage, cannot support consolidated satisfaction for multiple years. Failure of both requirements renders the assessments legally unsustainable. en-us Wed, 29 Jul 2026 00:00:00 +0530 Tue, 22 Sep 2026 08:17:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=799420 Section 153C jurisdiction over a person other than the searched person depends on the deemed search date, determined by recording satisfaction or receiving records. Where satisfaction was recorded in the deemed search year 2022-23, section 153C(3) did not permit proceedings for that year; any reassessment recourse lay under section 147. Jurisdiction also requires a satisfaction note identifying material specifically relating to that person and linking it to alleged escaped income for the relevant assessment years. General references to electronic evidence, or a ledger already contained in regular books without that linkage, cannot support consolidated satisfaction for multiple years. Failure of both requirements renders the assessments legally unsustainable. Case-Laws Income Tax Wed, 29 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=799420