The Supreme Court has held that the date on which the Panchnama was last drawn is the starting point of the two-year limitation for completing the block assessment proceedings under the Income Tax Act 1961.
The division bench of Justice M.R. Shah and Justice C.T. Ravikumar has upheld the order of the Delhi High Court in which it was held 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.
The two warrants of authorization under Section 132(1) for carrying out the search at the bank locker with Canara Bank, Kamla Nagar, were issued on March 13 and March 26, 2001.
During the execution of the search warrants dated March 13, 2001, the Income Tax authorities got information about a locker belonging to the appellant or assessee in a bank. As a result, on March 26, 2001, a second authorization for searching the locker was issued, and it was carried out on March 26, 2001.