For limitation U/s. 158BE, period is to be counted from the date on which the direction U/s. 142(2A) is served on the assessee

CIT Vs Amar Nath Arora (Rajasthan High Court) Notice was issued under section 158BC on 29-10-1999 according to the provisions of section 158BE, the period of two years would start from 28-2-1999 from the end of the month in which the search was car­ried out. Therefore, assessment ought to have been passed before 28-2-2001. However, in the interregnum period , the assessing officer had ordered to furnish the audit report as required under sub-section (2A) of section 142 on 18-1-2001 which was required by the assessee on 23-1-2001. The audit report was submitted by the assessee on 17-7-2001.  ...