action in bringing the impugned additions within the purview of block assessment under
Chapter XIV-B was in accordance with ... block period;
(b) the total undisclosed income relating to the block period shall not include the
income assessed in any regular assessment as income
158BA , the b lock
assessment is in addition to regular assessment and it is not in
place of regular assessment. If an officer starts disallowing ... additions made in the block assessments. Since the matter was
considered by CIT (A) in the block assessment
stated that the issue of non-genuineness was
covered under the block assessment period u/s.158BD ... Others. It is also not disputed in this case that the block
assessment made by the Assessing Officer was quashed by the Tribunal
while order
department against the order of the CIT(A) relating to block assessment from 1.4.96 to 21.1.2003.
2 Various grounds of appeal have been taken ... length by AO on pages 3 to 28 of impugned block assessment order. The main findings given by the AO are summarized in para
years.
Provided further that assessment or reassessment, if any,
relating to any assessment year falling within the period of six
assessment years referred ... assessee to furnish
returns for each assessment year falling within the six assessment years
immediately preceding the assessment year relevant to the previous year
years.
Provided further that assessment or reassessment, if any,
relating to any assessment year falling within the period of six
assessment years referred ... assessee to furnish
returns for each assessment year falling within the six assessment years
immediately preceding the assessment year relevant to the previous year
section 132 of the Act on 3/11/2000. In the block assessment which comprised of the block period including the period 1/4/2000 ... undisclosed income for the block period. It is the stand of the revenue that the addition in the block assessment was deleted because the Tribunal
declaring undisclosed loss of Rs.1,50,00,244/-. A block assessment
order was passed by the AO on 31st December, 2002 accepting the undisclosed ... dated cheques registers etc. were found. At para 13 in the block
assessment order, the AO held as follows :
" During the course of business
assessment order passed u/s.143(3) in the case of Shri
Mangatram M. Arora for Assessment Year 1999-2000, copy of
assessment order passed ... Assessment Year 1997-98, Rs.1,17,420/- for
Assessment Year 1998-99 and Rs.2,28,265/- for Assessment Year
notice u/s.
158BD beyond the limitation period and hence the block assessment
is null & void and liable to be quashed ... satisfaction note should
precede the date of Block assessment order passed u/s. 158BC . In
the above case , satisfaction note has been made after
