Block assessment additions must rest on incriminating search material, not post-search inquiry or unconnected bank records.

Block assessment under Chapter XIV-B is limited to undisclosed income detected as a result of search, so additions cannot rest on material unconnected with the search. Bank statements not recovered during search could not support block assessment additions because they were not found as search material. Likewise, gifts already disclosed in regular returns could not be treated as undisclosed income where only gift deeds and affidavits were found during search and no incriminating material showed the gifts to be bogus; post-search inquiry and suspicion were insufficient. The Tribunal's deletion of both additions was therefore upheld.

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Issues: Whether additions made in block assessment could be sustained when the bank statements relied upon were not found during search, and whether the gifts disclosed in regular returns could be brought to tax as undisclosed income in the absence of incriminating material found during search.

Analysis: Block assessment under Chapter XIV-B is confined to undisclosed income detected as a result of search. The bank statements were not recovered during search and were not relatable to any search material, so they could not form the basis of block assessment additions. As to the alleged gifts, only gift deeds and affidavits were found during search, while the alleged falsity of the gifts rested only on post-search inquiry and suspicion. No incriminating material was found to show that the gifts were bogus, and the gifts had already been disclosed in the regular returns.

Conclusion: The additions relating to both the bank statements and the gifts were outside the permissible scope of block assessment and were rightly deleted.

Final Conclusion: The appeal failed because no substantial question arose against the Tribunal's view that block assessment must rest on evidence unearthed in search and not on material gathered independently thereafter.

Ratio Decidendi: In block assessment proceedings, additions can be made only on the basis of incriminating material found as a result of search, and not on post-search inquiries or on material unconnected with the search.

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