FACTUAL MATRIX

1. This appeal is by the assessee challenging the order passed by the Tribunal on various grounds, including the findings recorded by the appellate Tribunal that the appellate Tribunal has no jurisdiction to examine the legality of the action of the authorizing officer anterior to the assessment officer, commencing the assessment proceedings.

2. On 05.12.1995, search operations were carried out in the assessee’s premises. On the conclusion of the search operations on 05.12.1995, the authorized officer clamped prohibitory order under Section 132 in respect of certain jewelleries, books of accounts etc., found at the time of search. Later on, on 24.01.1996. the authorized officer prepared one more panchanama in which the prohibitory order passed under Section 132(3) on 05.12.1995 was lifted. The books of accounts, jewelleries, etc., which were earlier kept under the prohibitory order were released. There was no seizure effected on 24.01.1996 when the search proceedings were stated to be concluded in the panchanama. It states, the prohibitory order was passed on 05.12.1995 itself. Thereafter, an order of block assessment under Section 158(B)(C) of the Income