Search-based income tax assessments after s132(3) restraint orders: limitation under s153B ran from last valid panchanama; assessments quashed.

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....Assessments pursuant to search were held time-barred under s.153B because the search legally concluded on 20.02.2021, when the authorised officer completed the physical search and drew the last valid panchanama; the later visit on 20.04.2021 merely lifted a restraint under s.132(3) without any further search activity or fresh authorisation and could not extend limitation. The restraint orders under s.132(3) were also found invalid as the records did not show why seizure was "not practicable," and, in any event, revocation beyond the CBDT-mandated one-month period rendered subsequent panchanamas incapable of extending limitation. Consequently, assessments for AYs 2020-21 and 2021-22 were quashed as barred by limitation. - ITAT....