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2018 (12) TMI 469

Assessment u/s 158BE - period of limitation prescribed u/s.158BE(1)(b) - date of ending the search - ITAT held that the Assessment order dated 23.02.2000 is passed beyond the period of limitation prescribed u/s.158BE(1)(b) - Held that:- In the process, the Tribunal relied on the decision of Delhi High Court in case of CIT Vs. Shri S. Katyal (2008 (11) TMI 46 - HIGH COURT DELHI) wherein facts which .....

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of 6th February, 1998 also clearly shows that no articles or things were found or seized. Infact, the search commenced at 11.00 a.m. and ended about in 35 minutes. - No hesitation in accepting the findings and conclusion of Tribunal. No question of law arises. - Income Tax Appeal No. 691 of 2016 - Dated:- 4-12-2018 - AKIL KURESHI AND M.S. SANKLECHA, JJ. Mr. Suresh Kumar for the Appellant. Mr. .....

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closed at 3.45 p.m. temporarily. According to the Department, further search was carried out on 6th February, 1998. The panchnama of the proceedings records that no documents or articles were found or seized. It also records that the search commenced at 11.00 a.m. and was closed at 11.35 a.m. The Assessing Officer passed the order of assessment on 23rd February, 2000. In this context, the questio .....

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ld that on 3rd January, 2001 i.e. the date which the Revenue wanted to be believe the search had ended, nothing was found or seized. All that was done on 3rd January, 2001, according to the High Court was that the seals were removed from the cash box and the almary and the keys were handed back to the assessee. It was in the nature of revocation of the seizure order passed earlier. 5. Facts are su .....

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