The Tribunal held that the assessment proceedings were on extraneous facts and evidence other than those referred to in the satisfaction note and which were basis for issuing notice under section 153C of the Act. The incriminating material in regard to the assessee has to pertain to the AYs in question. The authorities below were not justified in making assessment, not based upon incriminating material mentioned in the satisfaction note and thus acted beyond jurisdiction and scope of section 153C / 143(3) of the Act. Order was quashed. (AY.  2013-14)