The assessee’s block assessment under section 158BC was completed without issuance of notice under section 143(2). The assessee raised this jurisdictional issue before the High Court. The Court held that where a block assessment is completed under section 143(3) read with section 158BC, issuance of notice under section 143(2) is mandatory and omission to issue such notice is not a procedural irregularity but goes to the root of the jurisdiction. Since the Revenue failed to establish that notice under section 143(2) had been issued, the block assessment was held to be invalid and was quashed. The assessee had disclosed the impugned transaction in the regular return, and the same had been accepted in scrutiny assessment under section 143(3). During block assessment, the Assessing Officer relied upon material collected during post-search investigation to make an addition. The High Court held that Chapter XIV-B applies only to undisclosed income evidenced by material found during the course of search. Material gathered after the conclusion of the search during subsequent enquiries cannot be regarded as incriminating material found during the search and therefore cannot justify an addition in block assessment. Accordingly, the assessment was held to be beyond the scope of Chapter XIV-B. ( ITA No. 527 of 2017, dated 08-07-2026)