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In favour of revenue.The issues arising from the assessment order as challenged by the assessee before the Tribunal were on the question of undisclosed investments as also the undisclosed income detected under four separate heads of under-invoicing, undisclosed sales, investments in unaccounted purchases, and interest income.

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Section 158BB of the Income-tax Act, 1961—Block assessment— There is lack of material insofar as the prior years of the block period, but the same has been held to be inconsequential, in so far as the A.O being conferred with the power to make assessment in the best of his judgment, therefore the AO was perfectly justified in carrying out an assessment on the best of judgment, making estimations on the basis of the materials recovered- Tribunal was correct in having affirmed the order of the CIT (Appeals) confining the additions made with respect to under-invoicing of sales to the assessment year 2000-01 when there was indicated a consistent practise of such under-invoicing- Tribunal was correct in holding that there could be no estimation carried out for the other years in the block period when there were no documents seized to evidence such under-invoicing having been carried out in the earlier years - CIT V/s ORMA MARBLE PALACE (P.) LTD. - [2019] 9 ITCD Online 93 (KER)

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