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Section 150 of the Income-tax Act, 1961 - Income escaping assessment - In pursuance of an order on appeal etc. Observation of Tribunal in assessee's appeal against block assessment, that additions by way of undisclosed income to assessee's income by applying provisions of sections 68 to 69C could not be made in a block assessment of assessee and same could be made in regular assessments, and that too of two companies, could not be said to be a 'finding' or 'direction' within meaning of section 150 for reopening assessee's assessment beyond a period of six years. The observation of the Tribunal in the assessee's appeal against block assessment, that additions by way of undisclosed income to the assessee's income by applying provisions of sections 68 to 69C could not be made in block assessment of the assessee and the same could be made in regular assessments, and that too of two companies, could not be said to be a 'finding' or 'direction' for reopening assessee's assessment beyond a period of six years, as the alleged undisclosed income if at all taxable, would be taxable in the regular assessment of the two companies and not in the regular assessment of the assessee. S.N. Inamdar, K. Gopal and Jitendra Singh for the Petitioner. Vimal Gupta and P.S. Sahadevan for the Respondent. JUDGMENT J.P. Devadhar, J. :- These two petitions are filed to challenge two notices issued under section 148 of the Income Tax Act, 1961 ('Act' for short) both 20-12-2006 relating to the assessment years 1997-98 and 1998-99. 2. The petitioner is engaged in the business of distribution of Indian made foreign liquor. The petitioner ('assessee' for short) carried on business in the name of his proprietary concern M/s Avadh Liquors. On 12-8-1998 a search action under section 132 of the Act was carried out at the business premises of the assessee. During the course of search statement of the assessee was recorded under section 132(4) of the Act to the effect that the assessee has admitted undisclosed income of Rs. 1.25crores for the block asst. yrs� 1-4-1988 to 12-8-1998. The assessee retracted the said statement recorded on 12-8-1998 by filing an affidavit on 13-8-1998. However, on the…

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