Section 158BE – A panchnama which does not record a search does not extend limitation

Asstt. Commissioner of Income Tax Vs Shree Ram Lime Products Ltd (ITAT Jodhpur Special Bench)

Reckoning point to compute the time limit will be drawing of last panchnama in respect of any authorization issued in a particular case. However, it has already been held that the “last panchnama” as relevant for Explanation 2 to section 158BE will be the panchnama which show the conclusion of the search. Panchnama dated 3rd January, 2003 in the present case has not recorded the conclusion of se

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