In Brief
The Supreme Court dismissed appeals by assesses challenging assessment orders as time-barred under the Income Tax Act, 1961. The core issue was whether the two-year limitation for block assessment begins from the date of the last Panchnama drawn during a search or from the date of the last authorization issued. The Court held that the relevant date is when the final Panchnama is drawn, not when authorizations are issued. This interpretation aligns with Explanation 2 to Section 158BE, which deems authorization executed upon conclusion of search as recorded in the last Panchnama. The decision ensures that the entire material collected across multiple searches and Panchnamas informs the limitation period, preventing the provision from being rendered meaningless.
The lawyer headnote and full judgment text are available to registered users.