Block assessment limitation turns on the final panchnama date; search concluded on 31 January 2000, so the assessment was timely.

Limitation for a block assessment under Section 158BE depends on the date the search is concluded as recorded in the last panchnama under Explanation 2(a). The court treated the proceedings on 31 January 2000 as the operative end of the search because the restraint order under Section 132(3) was lifted, the keys were returned, and the panchnama recorded final conclusion of the search at 15:30 hours. The earlier date of 8 December 1999 was rejected for limitation purposes, and the assessment was held to be within time.

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Issues: Whether the block assessment order was barred by limitation under Section 158BE of the Income-tax Act, 1961, having regard to the date on which the search was concluded and the panchnama drawn on 31 January 2000.

Analysis: The period of limitation under Section 158BE turns on the conclusion of search as recorded in the last panchnama, by virtue of Explanation 2(a). The Court held that the proceedings on 31 January 2000 were not a mere formal or inconsequential step: the restraint order under Section 132(3) was lifted, the keys were returned, and the panchnama recorded that the search finally concluded at 15:30 hours. On that basis, the search was treated as ending on 31 January 2000, and not on 8 December 1999. The Court rejected the contention that limitation had to be reckoned from the earlier date.

Conclusion: The assessment was within limitation, and the question was answered in favour of the Revenue.

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