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Section 158BD, read with section 158BI of the Income-tax Act, 1961 - Block assessment in search cases - Undisclosed income of any other person - For purposes of section 153A/153C Assessing Officer can take into consideration material other than what was available during search operation for making an assessment of undisclosed income of assessee [In favour of revenue] The question of law agitated before the Tribunal was whether, for the purpose of computing income under section 153A/153C, the Assessing Officer was required to confine himself only to the material found during the course of search operations. The Tribunal held against the assessees. Held that by virtue of section 158B-I the various provisions of Chapter XIV-B are made inapplicable to proceedings under section 153A/153C. The effect of this is that while the provisions of Chapter XIV-B limit the inquiry by the Assessing Officer to those materials found during the search and seizure operation, no such limitation is found insofar as section 153A/153C is concerned. Therefore, it follows that for the purposes of section 153A/153C the Assessing Officer can taken into consideration material other than what was available during the search and seizure operation for making an assessment of the undisclosed income of the assessee. CASES REFERRED TO CST v. H. M. Esufali, H. M. Abdulali [1973] 90 ITR 271 (SC) (para 21), Manish Maheshwari v. Asstt. CIT [2007] 289 ITR 341 (SC) (para 18) and Santosh Hazari v.Purushottam Tiwari (dead) [2001] 251 ITR 84 (SC) (para 19). JUDGMENT Madan B. Lokur, CJ. - This batch of appeals filed under section 260A of the Income-tax Act, 1961 ("the Act") has been preferred against a common order dated November 26, 2010, passed by the Income-tax Appellate Tribunal, Hyderabad Bench "A", Hyderabad. 2. The assessees before us are Gopal Lal Bhadruka, his son, Avadesh Bhadruka, and their firm, Ahura Holdings. In fact, the firm, Ahura Holdings, has two other partners but they are not concerned with these proceedings. Ahura Holdings is engaged, inter alia, in real estate and at the relevant time it was developing a property in the Secunderabad cantonment. 3. On June 26, 2006, and June 27, 2006,…

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