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“block assessment”

Search & SeizureSection 158BCSection 158BC4,282 judgments

The decision most relied on for block assessment is CIT v. RRJ Securities Ltd. (380 ITR 612), cited in 689 judgments on BharatTax.

Leading authorities on block assessment

CIT v. RRJ Securities Ltd.
380 ITR 612 · 2016 · High Court
689
citing judgments

Completed assessments can be interfered with under Section 153A or 153C only on the basis of incriminating material unearthed during the search, necessitating a direct correlation between the discovered material and the power to assess or reopen concluded assessments.

SSP Aviation Ltd. v. Deputy Commissioner of Income Tax
346 ITR 177 · 2012 · High Court
308
citing judgments

For a non-searched person under Section 153C, the relevant six assessment years are counted backward from the assessment year in which the search was conducted, as prescribed by the first proviso to Section 153C(1).

PCIT v. Ojjus Medicare (P) Ltd.
465 ITR 101 · 2024 · High Court
277
citing judgments

For assessments under Section 153C, the commencement point for calculating the six or ten assessment year block period is the date of issuing the Section 153C notice, or the date of the satisfaction note/handing over of books, as clarified by the first proviso to Section 153C(1).

Manish Maheshwari v. ACIT
289 ITR 341 · 2007 · Supreme Court
237
citing judgments

A block assessment under Chapter XIV-B of the Income-tax Act requires a prior search conducted under Section 132 or a requisition of documents/assets under Section 132A. This fundamental condition precedent applies to block assessments, including those concerning other persons under Section 158BD.

CIT v. Jasjit Singh
155 Taxmann.com 155 · 2023 · Supreme Court
235
citing judgments

For assessments under Section 153C concerning a non-searched person, the relevant date for calculating the block of assessment years is the date on which the jurisdictional Assessing Officer of that person assumes possession of the seized material, not the date of the original search. This date determines the look-back period for reopening assessments under Section 153A read with 153C.

Rishabchand Bhansali v. Dy. CIT
267 ITR 577 · 2004 · High Court
202
citing judgments

The previous approval required for assessment orders under provisions like Section 158BG or Section 153D is an administrative power and an internal matter, not deciding the assessee's rights. A mere irregularity in granting such administrative approval does not vitiate the assessment order.

P.R. Metrani v. CIT
287 ITR 209 · 2006 · Supreme Court
187
citing judgments

Section 132 of the Income Tax Act is a self-contained code governing search and seizure operations. The books of accounts, documents, valuables, or statements recorded during a search can be used as evidence in any subsequent proceedings under the Act, and the section outlines the conditions for issuing warrants of authorization.

CIT (Central) v. Kabul Chawla
2015 SCC OnLine DEL 11555 · 2015 · Reported
186
citing judgments

No addition can be made in respect of a completed assessment in the absence of incriminating material, especially when considering the object and purpose of Section 153-A.

Judgments citing block assessment

Vision Exports, Moradabad vs. Assistant Commissioner of Income Tax, Central Circle, Moradabad

The appeal of the assessee is allowed

ITA 2361/DEL/2023[2017-18]Status: DisposedITAT Delhi13 Jun 2025AY 2017-18

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharmaassessment Year: 2017-18 Vision Exports, Vs Acit, Faridpur, Sambhal Road, Central Circle, Moradabad – 244 001, Moradabad. Uttar Pradesh. Pan: Aajfv0634Q (Appellant) (Respondent) Assessee By : Shri Chetan Agarwal, Ca; Shri Mohammad Ammar, Ca & Shri Tariq Nafees, Advocate Revenue By : Shri Amit Katoch, Sr. Dr Date Of Hearing : 23.04.2025 Date Of Pronouncement : 13.06.2025 Order Per Anubhav Sharma, Jm: This Appeal Is Preferred By The Assessee Against The Order Dated 23.06.2023 Of The Commissioner Of Income-Tax (Appeals), Lucknow-3 (Hereinafter Referred To As The Ld. First Appellate Authority Or ‘The Ld. Faa’, For Short) In Appeal No.Cit(A), Lucknow-3/10314/2018-19 Arising Out Of The Appeal Before It Against The Order Dated 30.12.2018 Passed U/S 143(3) Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) By The Acit, Central Circle, Moradabad (Hereinafter Referred To As The Ld. Ao).

For Appellant: Shri Chetan Agarwal, CAFor Respondent: Shri Amit Katoch, Sr. DR
Section 127Section 132Section 142(1)Section 143(2)Section 143(3)

stand alone basis without reference to any other material discovered during search and seizure operations would not empower the Assessing Officer to make a block assessment merely because any admission was made by the assessee during search operation. [emphasis supplied]” 17. Thus here in the case of assessee the statement