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Extension of time limit for completing block assessment under section 482 of the Criminal Procedure Code. Analysis: The petitioner sought an extension in the time limit for completing the block assessment of a non-petitioner in compliance with a previous court order. The non-petitioner had filed a return of income under protest for a block period, declaring nil undisclosed income. The Department required more time for deep inquiries due to the non-cooperation of the assessee. The petitioner requested either completion within the statutory period or a six-month extension. The petitioner argued that section 158BE allows one year for passing the order under section 158BC. Due to the non-cooperation of the assessee, detailed inquiries were necessary. The petitioner requested an extension of six months for assessment completion. The non-petitioner's counsel vehemently opposed the extension, citing the recovery of cash and the previous court order directing assessment completion within one month. The court considered the need for vigorous inquiries into the non-petitioner's income due to the total denial by the assessee. The court noted the Department's bona fides in completing the assessment promptly. The court extended the time limit for three months, emphasizing that frequent extensions would not be granted. The court clarified that the period of limitation under section 158BE is directory and can be curtailed in appropriate circumstances. In conclusion, the court granted a three-month extension for completing the assessment, highlighting the importance of timely completion and the discretionary nature of the statutory time limit. The non-petitioner retained the right to challenge the assessment on limitation grounds if desired.
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