Sec. 158BC of Income Tax Act, 1961— Block assessment —Once search commences it has to come to an end with the search party leaving the premises whether any seizure is made or not. and the limitation for completion of block assessment is expressly provided under section 158BE which clearly declares that it is the execution of the last of authorisation which is to be taken into consideration - If subsequent authorisation/panchnama is illegal then limitation cannot be counted from such illegal authorisation/panchnama, therefore, the panchnamas drawn based on authorisation is bad in law and therefore the limitation cannot be counted from it- The period between the second last panchnama and the last panchnama is almost one year for which there is no explanation given by the Revenue and as per section 132(8A), the said prohibitory order has come to an end, therefore, the assessment order is barred by limitation, hence, the block assessment order is quashed on this jurisdictional issue - NARANG INTERNATIONAL HOTELS PVT. LTD. V/s DEPUTY CIT - [2020] 185 ITD 324 (ITAT-MUMBAI)