Block Assessment – Material obtained during search showing a variation in expenditure may be considered as evidence for disallowance of expenditure

Whether the material obtained during search showing a variation in expenditure may be considered as evidence for dis allowance of expenditure for a block period u/s 158BB of the Act and would not amount to assessment on estimation basis? It has been held that the process of estimation cannot be arrived at while framing assessment, in terms of Section 158BB of the Act but assessment can be framed on the basis of material received during the course of search and seizure. Since the spiral pads, the basis of assessment in the year 2003-04 and 2004-05, were recovered during the search carried out ...