( 1 ) THIS is an appeal under Section 260-A of the income-tax Act, 1961 (in short the Act ). Challenge in the appeal is to the conclusions of the Income-tax appellate Tribunal, New Delhi (in short tribunal ) arrived at in ITA (SS) No. 70/del/96 holding that provisions relating to block assessment, in terms of section 158ba are not applicable to the facts of the case.

( 2 ) FACTUAL scenario so far as relevant is as follows:

SEARCH and sseisure operation were conducted on a business group known as Kohl. I Group on 1/11/1996. As it was noticed that assessee was having close links with the said groups a search under section 132 of the Act was also conducted at the residential premises of the assessee on 30/11/1996. Assessee was found to be engaged in the business of property dealing, as his main source of income, was found to be commission earned for making arrangements for hiring out or letting out properties and from purchase and sale of immovable properties. Assessing officer issued notice under Section 158bc of the Act on 10/6/1997 calling upon the assessee to file return for the block period ending on 30/11/1996. Assessee filed return stating that there was no undisc