On writ petitions challenging notices issued under section 153C contending that, in the absence of any incriminating material against the third party assessees having been seized during the search of the searched party under section 132, pertaining to the assessment years which were proposed to be reopened, the assumption of jurisdiction by the Assessing Officer was illegal and unsustainable,  allowing the petitions,  the Court held that    except in two writ petitions forming part of this batch against the invocation of section 153C in respect of the assessment years 2013-14 to 2020-21, no incriminating material had been gathered or obtained. The flow of events contemplated under section 153C being firstly the receipt of books, account, documents or assets by the jurisdictional Assessing Officer, an evaluation and examination of their contents and an assessment of the potential impact that they would have on the total income for the six assessment years immediately preceding the assessment year pertaining to the year of search and the “relevant assessment year”. It was only when the Assessing Officer of the assessees was satisfied that the materials coming into his possession were likely to “have a bearing on the determination of the total income” that notice under section 153C could be issued. Abatement would thus be a necessary corollary of that notice. The Department had erroneously proceeded on the assumption that the moment any material was recovered in the course of a search or on the basis of a requisition made, they were empowered in law to assess or reassess for all the six assessment years immediately preceding the assessment correlatable to the search year or the “relevant assessment year” as defined in Explanation 1 of section 153A. Such approach was unsustainable and contrary to the precedents. That the satisfaction notes of the jurisdictional Assessing Officers had failed to record any reasons as to how the material discovered and pertaining to a particular assessment year was likely to “have a bearing on the determination of the total income” for the year which was sought to be abated or reopened in terms of the notices. The satisfaction notes established that the jurisdictional Assessing Officers had proceeded on the premise that the moment incriminating material was unearthed in respect of a particular assessment year, they had the jurisdiction and authority to invoke section 153C in respect of all the assessment years which could otherwise form part of the “relevant assessment year” as defined in section 153A. Such understanding of the provisions of section 153C was erroneous and unsustainable. The discovery of material likely to implicate the assessee and impact the assessment of total income for a particular assessment year was not intended to set off a chain reaction on all assessment years which could form part of the “relevant assessment year”. This, more so since none of the satisfaction notes had recorded any reasons of how that material was likely to materially influence the computation of income for those assessment years. Therefore, the satisfaction notes would have to evidence a formation of opinion that the material is likely to be incriminating for more than a singular assessment year and warranting proceedings under section 153C for the assessment years in addition to those to which the material may be directly relatable. Hence the notices issued for the assessment years 2013-14 to 2020-21 in all but the two petitions were quashed. Dismissing the petitions (W. P. (C) Nos. 3007 and 3019 of 2023), that the satisfaction notes in these petitions had alluded to incriminating material having been recovered for the assessment years 2013-14 and 2014-15, respectively, and the materials that were correlatable had been specifically identified. All other contentions of parties could be raised in the ongoing proceedings.  (AY.2013-14 to 2020-21)