https://www.taxtmi.com/caselaws?id=62046 In a block assessment against an "other person" under the search provisions, limitation was held to run from the notice issued to that person, so the assessment was not time-barred. A challenge based on absence of a hearing before the Commissioner's approval also failed, as audi alteram partem was not extended beyond the statute. However, additions founded on third-party statements and search material could not stand without disclosure of the relied-upon material and a fair opportunity to rebut it. The assessment was therefore set aside for fresh adjudication after supplying the material and allowing cross-examination where the statements were used. en-us Tue, 20 Apr 1999 00:00:00 +0530 Mon, 17 Jan 2011 18:19:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=62046 In a block assessment against an "other person" under the search provisions, limitation was held to run from the notice issued to that person, so the assessment was not time-barred. A challenge based on absence of a hearing before the Commissioner's approval also failed, as audi alteram partem was not extended beyond the statute. However, additions founded on third-party statements and search material could not stand without disclosure of the relied-upon material and a fair opportunity to rebut it. The assessment was therefore set aside for fresh adjudication after supplying the material and allowing cross-examination where the statements were used. Case-Laws Income Tax Tue, 20 Apr 1999 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=62046