Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
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HC held that the Block Assessment Order dated 28.03.2002 under Section 158BC of the Income Tax Act was valid and within prescribed limitation. The search spanning multiple dates (08.12.1999, 21.01.2000, and 02.03.2000) with partial document seizure did not invalidate the assessment. The Prohibitory Order under Section 132(3) was not considered a "deemed seizure", and the assessment was completed within the statutory timeframe. Given the block period covering 1990-1991 to 1999-2000, the Appellate Tribunal was directed to expedite the pending appeal considering the substantial time already elapsed in litigation.
HC held that the Block Assessment Order dated 28.03.2002 under Section 158BC of the Income Tax Act was valid and within prescribed limitation. The search spanning multiple dates (08.12.1999, 21.01.2000, and 02.03.2000) with partial document seizure did not invalidate the assessment. The Prohibitory Order under Section 132(3) was not considered a "deemed seizure", and the assessment was completed within the statutory timeframe. Given the block period covering 1990-1991 to 1999-2000, the Appellate Tribunal was directed to expedite the pending appeal considering the substantial time already elapsed in litigation.
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