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Section 158BD of the Income-tax Act, 1961 - Block assessment in search cases - Undisclosed income of any other person - Block periods 1-4-1988 to 8-12-1998 - It is a well-settled legal position and is also clear from a bare reading of relevant provisions that an addition under section 158BD can be made only in respect of material disclosed at time of search or pursuant to any inquiry made in relation to search; where addition made by Assessing Officer in respect of unexplained investment in property was solely based upon report made by District Valuation Officer, which could not be stated to be material found during the course of search, addition was not justified [In favour of assessee] It is a well-settled legal position and is also clear from a bare reading of the relevant provisions that an addition under section 158BD of the Act can be made only in respect of the material disclosed at the time of search or pursuant to any inquiry made in relation to the search. Where addition made by the Assessing Officer in respect of unexplained investment in property was solely based upon the report made by the District Valuation Officer, which could not be stated to be material found during the course of search. Held that no other material had been found at the time of search to indicate that the assessee had spent any amount in excess of what had been recorded in the books of account regularly maintained by it. The addition in question was beyond the scope of the block assessment. CASES REFERRED TO Smt. Amiya Bala Paul v. CIT [2003] 262 ITR 407 (SC). M.R. Bhatt and Mauna M. Bhatt for the Appellant. JUDGMENT Ms. H.N. Devani, J. - In this appeal under section 260A of the Income-tax Act, 1961 (the Act), the appellant-Revenue has proposed the following question in relation to the block assessment period April 1, 1988, to December 8, 1998 : "Whether the Appellate Tribunal is right in law and on facts in confirming the order passed by the Commissioner of Income-tax (Appeals) deleting the addition of Rs. 27,31,200 made on account of unexplained investment in property by the assessee ?" 2. The assessee is assessed in the status of a Hindu undivided family. A search and…

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