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2023 (3) TMI 1200 - SC - Income TaxBlock assessment u/s 158BC/158BE - Period of limitation - time limitation for commencement of block assessment - scope of relevant date - whether the period of limitation of two years for the block assessment u/s 158BC/158BE would commence from the date of the Panchnama last drawn or the date of the last authorization? - HELD THAT:- As observed and held by this Court in the case of VLS Finance Limited [2016 (4) TMI 1133 - SUPREME COURT] the relevant date would be the date on which the Panchnama is drawn and not the date on which the authorization/s is/are are issued. It cannot be disputed that the block assessment proceedings are initiated on the basis of the entire material collected during the search/s and on the basis of the respective Panchnama/s drawn. Therefore, the date of the Panchnama last drawn can be said to be the relevant date and can be said to be the starting point of limitation of two years for completing the block assessment proceedings. If the submission on behalf of the respective assessees that the date of the last authorization is to be considered for the purpose of starting point of limitation of two years, in that case, the entire object and purpose of Explanation 2 to Section 158BE would be frustrated. If the said submission is accepted, in that case, the question which is required to be considered is what would happen to those material collected during the search after the last Panchnama. It cannot be disputed that there may be number of searches. Thus, the view taken by the High Court that the date of the Panchnama last drawn would be the relevant date for considering the period of limitation of two years and not the last date of authorization, we are in complete agreement with the view taken by the High Court. Appeal dismissed.
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