basis of his finding in the block assessment
order passed in the cases of both the assessees, he arrived at a conclusion
that income ... harping upon the observations made by the
Assessing Officer in the block assessment. We find that the ITAT has
examined this issue in detail
Virendra Gram, though not making separate disallowance as
covered by block assessment.
3. The Learned Commissioner of Income Tax (Appeals) has
erred in facts ... disallowances are made only after considering disallowances
made in the block assessment and the assessee will not be
entitled to any adjustment for disallowances made
Department Of Income Tax
IT A NO. 102/DEL/2007
Block Assessment 1.4.1996 to 18.12.2002
IN THE INCOME TAX APPELLATE TRIBUNAL
DELHI BENCH ... SHAMIM YAHYA, ACCOUNTANT MEMBER
I.T.A. No. 102/Del/2007
Block Assessment 1.4.1996 to 18.12.2002
Asstt. Commissioner of Income Tax, vs. M/s Daily
towards depreciation on the
basis of finding given in the block assessment order which has
already been decided in favour of the assessee ... operation was conducted on the assessee company on
21.11.00 and the block assessment u/s 158BC was made for the
period 1.4.90 to 21.11.00. While
from the date of search (03.08.2000) or from the
date of block assessment of Sh.Manoj Aggarwal (29.08.2002) or
even from the date on which ... invoking section 158BD was
not satisfied and accordingly quashed the block assessment made on the company
u/s 158BD read with section 158BC. If this
from the date of search (03.08.2000) or from the
date of block assessment of Sh.Manoj Aggarwal (29.08.2002) or
even from the date on which ... invoking section 158BD was
not satisfied and accordingly quashed the block assessment made on the company
u/s 158BD read with section 158BC. If this
premises of the assessee on 3rd of September, 1997
and a block assessment under sec. 158BC was passed on 27.9.1999. The
2
assessee has filed ... assessment proceedings, learned Assessing Officer has observed that in the
block assessment inquiries were made regarding the advertisement expenses
booked by the assessee
Officer of the searched person, it is after
the completion of block assessment in the case of searched person and as per
the decision ... Assessing Officer of the searched person before completion of block assessment
in the case of the searched person. It is also submitted that for these
care of the assessment to be made in cases of search & seizure. Such an assessment was popularly known as 'block assessment' because ... assessee to furnish returns for each assessment year falling within the six assessment years immediately preceding the assessment year relevant to the previous year
been settled that undisclosed income for the
purpose of block assessment has to be computed on the basis of seized
material. In other words ... assessment u/s
143(3) was made by the AO, then the assessment can be reopened, if it is
established that income has escaped assessment
