Vinod Chandran, J

The appeal raises a substantial question of law against the order of the Income Tax Appellate Tribunal; whether the limitation period has expired when the assessment order was passed under Section 158 BC of the Income Tax Act, 1961 ('Act', for short). Shorn of the unnecessary details, the brief facts to be noticed are that on due authorization, the premises of the assessee was searched under Section 132 of the Act on 16.03.2000. At the time of search, a panchnama was prepared seizing almost 3700 documents. A wooden almirah, with documents therein, found in the residential premises of the assessee was also issued with a restraint order under Section 132(3) of the Act. Later, there was a further search conducted of the documents and the articles kept in the almirah and seven documents were seized by a panchnama on the search conducted on 04.04.2000. The question urged before this Court is on the setting in of limitation by the time, the assessment order was passed on 24.04.2002. The limitation commences from the last day of the month in which the last panchnama was recorded.

2. The contention of the assessee-appellant as argued before us by the learned Couns