2011 (10) TMI 417

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....e has preferred this appeal challenging the order passed by the Tribunal which has upheld the block assessment order passed by the assessing authority, Challenging the said order the appellant has raised several grounds including the ground of limitation. If the order passed by the assessing authority is beyond the period of limitation then it would be an order without jurisdiction and if it is se....

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....5. In respect of the office premises they have visited the same on 30-11-1995 and 19-12-1995 and they have drawn the panchanama and according to them, the last drawn panchanama in respect of the office premises is 19-12-1.995 the period of two years is to be computed from the end of the month of the search. The last of panchanama being 19-12-1995 if one year period is taken into consideration it w....

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....of limitation. By virtue of an authorization the official visits the residential place and the official place, the search must be completed on the very same day and for the purpose of limitation, it is from that date the period of one year is to be computed. However, they visited the places without fresh authorization on the basis of earlier authorization and then made searches by virtue of the pr....