https://www.taxtmi.com/caselaws?id=219909 Where the assessee itself was searched and incriminating material was found in that search, the block assessment had to proceed under Section 158BC, not Section 158BD. Section 158BD applied only when undisclosed income of a person other than the searched person was assessed on material found in another person's search. Limitation for a Section 158BC assessment was governed by Section 158BE(1)(a), and later file noting could not change the statutory nature of the proceeding or extend time. As the assessment was completed after the prescribed period, it was barred by limitation. en-us Wed, 22 Aug 2012 00:00:00 +0530 Tue, 01 Jan 2013 11:54:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=219909 Where the assessee itself was searched and incriminating material was found in that search, the block assessment had to proceed under Section 158BC, not Section 158BD. Section 158BD applied only when undisclosed income of a person other than the searched person was assessed on material found in another person's search. Limitation for a Section 158BC assessment was governed by Section 158BE(1)(a), and later file noting could not change the statutory nature of the proceeding or extend time. As the assessment was completed after the prescribed period, it was barred by limitation. Case-Laws Income Tax Wed, 22 Aug 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=219909