Block assessment jurisdiction depends on actual handover of requisitioned material, not mere service of the warrant.

Block assessment jurisdiction under section 158BC arises only after requisitioned books, documents or assets are physically handed over to the income-tax authorities under section 132A. Mere service of the warrant of authorization or requisition is insufficient because the statutory scheme contemplates two distinct steps: requisition and actual delivery of the material. Where the requisitioned assets are not transferred into departmental possession, the requisition remains unconsummated and the block assessment machinery cannot be invoked.

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Issues: Whether jurisdiction to complete block assessment under section 158BC arises on service of the warrant of authorization under section 132A or only on physical handing over of the requisitioned books of account, documents, or assets to the income-tax authorities.

Analysis: Section 132A contemplates two distinct steps: first, issuance of requisition by the income-tax authority to the officer or authority in possession of the assets, and second, compliance by actual delivery of the requisitioned material. The statutory scheme in section 132A(3) shows that the provisions governing block assessment apply only where the requisitioned books, documents, or assets have been delivered to the requisitioning officer. Relying on the binding jurisdictional precedent and persuasive High Court authority, the Tribunal held that mere service of the warrant or requisition, without actual transfer of possession, does not satisfy the statutory requirement. Since the requisitioned material in the present case was never handed over to the Department, the requisition remained unconsummated and the block assessment machinery could not be invoked.

Conclusion: Jurisdiction to complete block assessment under section 158BC is conferred only upon physical handing over of the requisitioned material under section 132A, not upon mere service of the warrant of authorization.

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