Additions were made on the basis of abbreviated entries in notebooks seized during the search of a third party, alleging that they referred to the assessee, a former Highway Minister. The Tribunal held that the notebooks were merely dumb documents, containing no details regarding the nature of payment, purpose of payment or identity of the recipient. In the absence of corroborative evidence and after the retraction of the employee’s statement relied upon by the Revenue, the additions could not be sustained. The satisfaction note relating to the assessee was received by the jurisdictional Assessing Officer during assessment year 2022-23. The Tribunal held that jurisdiction under section 153C extended only to the six assessment years immediately preceding the relevant assessment year. Consequently, assessment year 2015-16 fell beyond the permissible period and the assessment for that year was held to be without jurisdiction and was quashed. The Tribunal held that, for assuming jurisdiction under section 153C, only a prima facie satisfaction is required. Since the seized material and the statement recorded during search prima facie connected the abbreviation “HW” with the Highway Minister during the relevant period, the satisfaction recorded by the Assessing Officer was sufficient to assume jurisdiction under section 153C. The Tribunal found the delay of 16 days in filing the appeal to be marginal and, in the interest of justice, condoned the delay.  (AY. 2015-16 to 2017-18).