Whether limitation period for completing assessment is to be seen from date of last panchnama?

Link of full case : https://taxlawsonline.com/agtlol.html...

[2024] 465 ITR 786 (Del)
[IN THE DELHI HIGH COURT]

ANURADHA BAKSHI
v.
PRINCIPAL COMMISSIONER OF INCOME-TAX

SATISH CHANDRA SHARMA C. J. and SANJEEV NARULA J.

October 19, 2023.

Playlist: Section 153A, 132

A.Y: 2015-16 | Assessee

Section 153A: Assessment in case of search or requisition

Section 132: Search and seizure

Question: Whether limitation period for completing assessment is to be seen from date of last panchnama?

1. The time period for completion of assessment u/s 153A would be 12 months from the end of the F.Y. in which the last authorization for search u/s 132 was executed.

2. An authorization is deemed to be executed on the conclusion of search as recorded in the “last panchnama” drawn in relation to a person, in whose case the warrant of authorization has been issued.

3. The limitation period for assessment warrants strict interpretation.

4. The A.O. inspected three distinct lockers belonging to the assessee.

5. Out of the three, two were searched both in March, 2021 and April, 2021, based on warrant dated 01.03.2021.

6. During the search executed in April, 2021 in respect of these two lockers, no seizures were made and consequently, a panchnama was drawn reflecting nil recovery.

7. The 3rd locker was examined on 29 April, 2021 on the basis of warrant of authorization issued on April 5, 2021.

8. This fact was reinforced by the panchnama, restraint order, and revocation order, issued on 29.04.2021 for the 3rd locker.

9. The search operation was ongoing process that definitively concluded on 29.04.2021 when the 3rd locker was inspected.

10. The assessment order of 31.03.2023 passed u/s 153A of the Act was not barred by limitation.

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Link for some important videos:

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2) WHETHER ASSESSEE HAS ALSO TO CHALLENGE THE FINDINGS OF THE A.O THAT NOTICE HAS BEEN SERVED?- https://www.youtube.com/watch?v=XbZWh...

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