Abatement of the six assessment years or the “relevant assessment year” under Section 153C would follow the formation of opinion and satisfaction being reached that the material received is likely to impact the computation of income for a particular assessment year or assessment years’ that may form part of the block of ten assessment years. In the present case AO recorded a Satisfaction Note that related to incriminating material for assessment years 2013-14 and 2015-16 and no incriminating material was found for assessment years 2014-15 and 2016-17 to 2020-21 and AO did not record reasons indicating how material pertaining to assessment years 2013-14 and 2015-16 would have a bearing on determination of total income for assessment years 2014-15 and 2016-17 to 2020-21. Thus, notices issued under Section 153C for the said years are not sustainable in law. SLP of the revenue dismissed on account of delay of 448 days and 474 days. (AY. 2014-15, 2016-17 to 2020-21)