Parallel search and regular assessments may proceed together, but the same income cannot be taxed twice.

Chapter XIV-B search assessment and regular assessment under section 143(2) operate in different fields: the block procedure addresses undisclosed income for the block period, while regular assessment proceeds on the return and disclosed income. The Assessing Officer may continue the regular assessment for the same assessment year during pendency of block assessment proceedings, but income already falling within the block assessment cannot be taxed again in the regular assessment. The section 143(2) notice was therefore not required to be stayed, subject to this anti-duplication limit.

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Issues: Whether, during pendency of block assessment proceedings under Chapter XIV-B on a search, the Assessing Officer can continue regular assessment proceedings under section 143(2) for the same assessment year.

Analysis: Chapter XIV-B provides a special procedure for assessment of search cases and is confined to undisclosed income forming part of the block period, whereas regular assessment under section 143(3) proceeds on the basis of the return and disclosed income. Since the two proceedings operate in different fields, they may proceed simultaneously for the same period, provided income already assessable in one proceeding is not again brought to tax in the other.

Conclusion: The notice under section 143(2) was not liable to be stayed, and the Assessing Officer could continue the regular assessment, but not in respect of income that was the subject-matter of the block assessment proceedings.

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