Block assessment jurisdiction fails when proceedings begin without a search warrant in the assessees' names.

Block assessment proceedings under section 158BC cannot be validly initiated without a search warrant in the assessees' names. On the facts noted, the proceedings for the block period were started without such warrants, and the Tribunal treated the initiation as without jurisdiction and ab initio void. The High Court further observed that no addition had been made in either matter on the basis of assets found in the lockers, reinforcing that interference was unnecessary. The operative point is that the absence of a search warrant in the assessees' names defeated the jurisdictional basis for block assessment initiation.

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Issues: Whether block assessment proceedings under section 158BC of the Income-tax Act, 1961 could be initiated in the absence of a search warrant in the assessees' names.

Analysis: The proceedings for the block period were found to have been initiated without search warrants in the names of the assessees. On that material, the Tribunal treated the initiation under section 158BC as without jurisdiction and ab initio void. The High Court also noted that no addition had been made in either case on the basis of assets found in the lockers, which further showed that no useful purpose would be served by interference.

Conclusion: The initiation of block assessment proceedings was held to be without jurisdiction in the absence of a search warrant in the assessees' names.

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