PETITIONER Vs. S.K. KATYAL

JUDGEMENT

(1.) THIS appeal under section 260A of the Income Tax Act, 1961 (hereinafter referred to as 'the said Act') is directed against the order dated 14.11.2006 passed by the Income Tax Appellate Tribunal in IT (SS) A No.302/Del/04 pertaining to the block period 01.04.1990 to 17.11.2000. The appellant/revenue is aggrieved by the fact that the Tribunal held the block assessment order to be beyond the time specified under section 158BE(1)(b) of the said Act.

(2.) ON the basis of a warrant of authorization dated 16.11.2000, a search, under the provisions of section 132 of the said Act, was conducted on 17.11.2000 in the residential premises of the assessee at E-147 Kalkajee, New Delhi. As per the panchnama drawn up on 17.11.2000, in the course of the search certain documents, cash and key no.765 of locker No. 725-B with Bank Of India, Nehru Place, New Delhi belonging to the assessee were purportedly seized. In the course of the said search conducted on 17.11.2000, amongst other things, jewellery was also found. The jewellery was inventorised and valued as per Annexure-5 to the panchnama. Paragraphs 8 and 9 of the panchnama are relevant and they are as follows :

(3.) NO further seizure was made from the said premises and on 03.01.2001 the Income Tax Officer (Inv) Unit-I, New Delhi passed the following revocation order :