Undisclosed income which is subject matter of block assessment cannot be made basis for reopening of assessment

HIGH COURT OF GUJARAT Prakash Jewellers Versus Assistant Commissioner of Income-tax SPECIAL CIVIL APPLICATION NO. 12394 OF 2002 SEPTEMBER 3, 2012 JUDGMENT Ms. Harsha Devani, J.  The petitioner, a partnership firm, has challenged the notice dated 22nd January, 2002 issued by the respondent under section 148 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) seeking to reopen its assessment for assessment year 1999-2000. 2. The facts of the case as stated in the petition are that on 27th January, 1999, search proceedings were conducted under section...