Assessment Order Barred by Limitation Due to Improper Extension Tactics u/s 158BE in Block Assessment Case.

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....Block assessment u/s 158BC - period of limitation u/s 158BE - In the case of the assessee herein on 07-11-2001, the investigation wing of department after almost one year has only converted the non-existent prohibitory order into deemed seizure, and therefore in the present case the panchnama dated 07-11-2001 is only for the purposes of extending the limitation period. - Therefore, the assessment order dated 28-11-2003 is barred by limitation - AT....