Revenue's Appeal Dismissed for Time Bar & Lack of Jurisdiction; Last Panchanama Crucial

The Revenue's appeal challenging a block assessment order was dismissed by the High Court as time-barred and lacking jurisdiction. The Court emphasized the significance of the last panchanama in search operations and cited a previous ruling declaring the block assessment as time-barred. Consequently, the Revenue's appeal was deemed nonviable and dismissed as infructuous on June 9, 2011.

---

---

Issues involved: Appeal filed by Revenue challenging block assessment order on grounds of being time-barred and bad in law.

Summary:
1. The Revenue raised 27 grounds in the appeal, with the main grievance at ground No.26 challenging the CIT(Appeals) order on the block assessment's timeliness.
2. The assessee's counsel referred to a High Court order declaring the block assessment as time-barred and without jurisdiction, rendering the Revenue's appeal obsolete.
3. The Departmental Representative acknowledged the High Court decision, conceding that the Revenue's appeal was no longer valid.
4. The High Court's order highlighted that the block assessment order dated 30.6.2005 was time-barred and lacked jurisdiction, emphasizing the importance of the last panchanama in concluding a search.
5. With the High Court's ruling on the block assessment's limitation, the Revenue's appeal was deemed nonviable.
6. Consequently, the Revenue's appeal was dismissed as infructuous on June 9, 2011.

---