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TMI Blog2007 (1) TMI 212X X X X Extracts X X X X X X X X Extracts X X X X ..... and cross-objection by the assessee are directed against the order of the learned CIT (A)-I, New Delhi, dt. 28th June, 2004 in an appeal against order under s. 158BC of the IT Act (the Act). 2. Whereas the Revenue challenges the deletion of addition made in the block assessment, in the cross-objection, the assessee challenges the validity of the assessment order on the ground that the same is ba ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e the search was originally conducted on 17th Nov., 2000 and since there was no reason to impose any prohibitory order, the limitation should commence from 17th Nov., 2000 itself. Thus, the assessment should have been completed on or before 30th Nov., 2002. For this purpose, he relied upon the decision of the Tribunal in the case of Shri S.K. Katyal vs. Dy. CIT in [IT(SS)A No. 302/Del/2004, dt. 14 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... years from the end of the month in which the last Panchnama was drawn. Thus, the time-limit is available upto 31st Jan., 2003 and hence the assessment made on 30th Jan., 2003 is within limitation period. He also invited our attention to the decision of Hon'ble Delhi High Court in Writ Petn. No. 4685 of 2000, dt. 15th Dec., 2006, wherein it was held that time-limit would begin from the date of the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... oncluded on 12th Dec., 2000 itself and since the same is the last Panchnama, so far as the appellant before us is concerned, the time-limit commences from the date of such last Panchnama. Accordingly, as per s. 158BE(1) r/w Expln. 2 thereto, the assessment shall be framed within two years from the end of the month in which last Panchnama was drawn. Accordingly, the assessment should have been comp ..... X X X X Extracts X X X X X X X X Extracts X X X X
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