Block Assessment: Additions not based on Incriminating Material found during search is not valid

Reelvant Extract of the Judgment Analysis and Findings 22. On the question of law presently before the court, the primary consideration is whether the AO had the jurisdiction to make the additions to the assessment under section 158BC of the Act. To analyze this, it is necessary to address the grounds of each such addition made, and assess if the AO had jurisdiction in conducting the block assessment within the meaning of section 158BC, or if this was indeed not within the purview of the AO’s jurisdiction. Section 158BC reads as follows: “Where any search has been conducted under section...