The High Court held that section 153C applies only for AYs where the AO has incriminating material relevant to that year. Without such material, reopening all 10 AYs mechanically is unjustified. In this case, satisfaction notes did not record how seized material had a bearing on the total income for the years reopened. The proceedings were quashed. The Supreme Court dismissed revenue’s SLP due to delay of 162 and 145 days and also on merits. (AY. 2015-16)