income that has escaped assessment for any assessment year and was inapplicable to any assessment of income for a block period. A time-limit ... lays down special procedure for assessment of search cases. As noted above, it deals with assessment of a "block period" as defined
search, several materials were seized on the basis of which a block
assessment was completed in the case of Manoj Aggarwal under Section ... nearly 19 months
had elapsed from the date of completion of block assessment of Manoj
Aggarwal before the notice under Section 158BD issued; that
poser is as to
whether it was possible to make the block
assessment with the addition of levy of
surcharge, in the absence of proviso ... proviso was added, whether
surcharge was payable in respect of block
assessment or not, was totally ambiguous and
unclear. The Court pointed out that some
Chapter XIV B, we
find that Sec.158B defines block period. Sec.158BA
authorise block assessment in the event concealment of
income is detected ... assessee
throughout all the assessment years in the block period for
the purpose of block assessment. Of course, the
presumption is rebuttable. In such circumstances
respondent No.5 herein, on the same date and finally the block assessment order, dated 31st January, 1997, passed under Section 158BC ... July, 1995 laying down special procedure for assessment of search cases. It deals with assessment of a
block period as defined in Clause
Bhuyan, learned Counsel for the Revenue submitted that the block assessment following search and seizure as per the provisions of Chapter ... computation of undisclosed income of the block period. Section 158BC provides the procedure for block assessment. To appreciate the procedure prescribed, we may quote herein
that the block assessment is in addition to the regular assessment in respect of each previous year included in the block period ; (b) means total ... block assessment shall not be included in regular assessment and other than undisclosed income is assessable in regular assessment under Section
assessment without there being compliance of the requirement of Section 145 before resorting to best judgment assessment?
(ii) Whether in taking resort to the block ... assessment without there being compliance of the requirement of Section 145 before resorting to best judgment assessment?
(ii) Whether in taking resort to the block
additions in the income of these three brothers were made qua Block
Assessment proceedings on the premise that consideration of the
said property was under ... impugned order has correctly stated the
facts under which the Block Assessment proceedings were initiated
by the Assessing Officer in respect of these assessees
addition to the regular assessment already done or to be
done. The assessment for the block period can only be done on
the basis ... make a distinction
between the block assessment and the regular assessment. In
the case of regular assessment, the AO is free to examine the
veracity
