Block assessment limited to search material; additions based on post-search enquiries were unsustainable and deleted.

Block assessment under Chapter XIV-B is confined to undisclosed income detected from search material and cannot be used as a substitute for regular assessment. Additions based only on enquiries made after the search, without linkage to material unearthed during search, fall outside that limited jurisdiction. The disputed additions were therefore unsustainable in block assessment and were deleted in favour of the assessee.

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Issues: Whether additions could be sustained in block assessment proceedings when they were not based on material found during search.

Analysis: The special procedure for block assessment is confined to assessment of undisclosed income detected as a result of search and is not a substitute for regular assessment. The additions in question were not shown to arise from any material unearthed in the search, but from enquiries made subsequently. In that situation, the block assessment jurisdiction could not be used to support the additions.

Conclusion: The additions were rightly deleted in block assessment proceedings and the issue is decided in favour of the assessee.

Final Conclusion: The appeal failed because the disputed additions were outside the limited scope of block assessment and were not referable to search material.

Ratio Decidendi: Block assessment under Chapter XIV-B is confined to undisclosed income revealed by search material and cannot be used as a substitute for regular assessment or for additions based only on post-search enquiry.

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