Block assessment cannot reopen recorded cash credits or commission expenses already shown in regular books.

Chapter XIV-B block assessment is confined to undisclosed income detected from search material and cannot be used to revisit entries already recorded in regular books. Additions for unexplained cash credits were deleted because the credits appeared in the books for the relevant year, the return due date had not expired on the date of search, and the appellate findings accepted creditor confirmations without perversity. Disallowance of commission expenditure was also deleted because the payment was already reflected in the regular records and the seized document was only a printout of those books.

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Issues: (i) Whether additions towards unexplained cash credits could be sustained in block assessment proceedings when the credits were already reflected in the regular books of account and the return for the relevant year was filed within the due date. (ii) Whether commission expenditure already recorded in the regular books of account could be disallowed in block assessment proceedings on the basis of a seized printout of those very books.

Issue (i): Whether additions towards unexplained cash credits could be sustained in block assessment proceedings when the credits were already reflected in the regular books of account and the return for the relevant year was filed within the due date.

Analysis: The credits were found to have been entered in the regular books for the relevant assessment year and the return date had not expired on the date of search. The material placed before the appellate authorities supported the genuineness of the transactions, and no perversity or error was shown in the factual findings accepting the creditors' confirmations. Chapter XIV-B is confined to undisclosed income detected as a result of search and is not a substitute for regular assessment.

Conclusion: The addition on account of unexplained cash credits was rightly deleted and the issue was decided in favour of the assessee.

Issue (ii): Whether commission expenditure already recorded in the regular books of account could be disallowed in block assessment proceedings on the basis of a seized printout of those very books.

Analysis: The disputed commission formed part of the total commission already allowed in the regular assessment, and the so-called seized document was only a printout of the regular books of account. In such circumstances, block assessment could not be used to re-examine and disallow a claim that was already reflected in the regular records.

Conclusion: The disallowance of commission was rightly deleted and the issue was decided in favour of the assessee.

Final Conclusion: No substantial question of law arose, as the impugned additions had been deleted on sustainable factual findings within the limited scope of block assessment proceedings.

Ratio Decidendi: Chapter XIV-B applies only to undisclosed income found on search material and cannot be invoked to substitute a regular assessment or to revisit transactions already recorded in the regular books of account.

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