https://www.taxtmi.com/caselaws?id=775030 ITAT Mumbai held that assessment orders were barred by limitation under Section 153B. The tribunal found that a search concluded on 26.03.2021, but authorities issued an invalid restraint order under Section 132(3) and conducted a subsequent visit on 24.05.2021. The restraint order was deemed invalid as it failed to specify reasons why items couldn't be seized initially, violating Section 132(3) requirements. The panchnama dated 24.05.2021 was not accepted as evidence of search conclusion since no actual search occurred - authorities merely visited premises to access previously restrained items. The tribunal ruled that limitation period crystallizes when search ends, and subsequent invalid restraint orders cannot extend this period. Since the valid search concluded on 26.03.2021, assessment orders passed beyond the statutory limitation period were quashed as time-barred. en-us Fri, 27 Jun 2025 00:00:00 +0530 Thu, 17 Jul 2025 12:35:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=775030 ITAT Mumbai held that assessment orders were barred by limitation under Section 153B. The tribunal found that a search concluded on 26.03.2021, but authorities issued an invalid restraint order under Section 132(3) and conducted a subsequent visit on 24.05.2021. The restraint order was deemed invalid as it failed to specify reasons why items couldn't be seized initially, violating Section 132(3) requirements. The panchnama dated 24.05.2021 was not accepted as evidence of search conclusion since no actual search occurred - authorities merely visited premises to access previously restrained items. The tribunal ruled that limitation period crystallizes when search ends, and subsequent invalid restraint orders cannot extend this period. Since the valid search concluded on 26.03.2021, assessment orders passed beyond the statutory limitation period were quashed as time-barred. Case-Laws Income Tax Fri, 27 Jun 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=775030