TaxTMI 
TaxTMI 
1998 (2) TMI 142
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....nder s. 158BC was issued by the Asstt. CIT (Inv.), Cir-1(1), Surat. Return of income for the block period was filed on 14th Feb., 1996 disclosing the total undisclosed income of Rs. 25 lakhs. The AO after scrutiny of the material found during the course of search worked out the total undisclosed income at Rs. 45,75,190 as under: . . Rs. A. For the period 1st April, 1995 to 6th Dec., 1995 16,81,931 B. For the period 1st April, 1995 to 31st March, 1995 26,84,652 C. Cash found during the earlier search on 8th Oct., 1994 1,77,000 3. Though a number of grounds have been raised before us the assessee disputes mainly the addition of Rs. 26,84,652 referred to supra. During the course of assessment proceedings it was submitted before t....
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....the block period is being calculated accordingly. In the instant case the incriminating papers had been found pertaining to asst. yr. 1995-96 as well as for the period 1st April, 1995 to 6th Dec., 1995. Hence, estimation is being done for this period only." 4. Shri S.N. Soparkar, the learned counsel for the assessee submitted that though the learned AO took note of the contents of the above noted circular, he failed to realise that only two papers for a sum of Rs. 10,000 and Rs. 20,000 referable to this period, i.e., Dec., 1994 were found by the search party and were relating to the transactions on which commission could be treated as the income of the assessee. The commission on such transaction would work out to less than Rs. 100 only, ....