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The assessee filed an appeal raising three grounds. One that the assessment year 1999-2000 cannot be taken up for consideration of block assessment, since it is beyond the six year period provided under Section 153A of the Act. The contention was advanced on the premise that the last of thesearchon 20.04.2005 was in 2006-2007 and the block years have to be computed from the date of the panchnama as prepared by the officer conducting the last of the searches. Yet another contention was with respect to the documents relied on to make additions, being not one seized in thesearchconducted and hence the proceedings under Section 153A read with Section 143 beingnon est. There was also an objection raised with respect to the computation of capital gains.

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Section 149 of the Income Tax Act, 1961 — Reassessment — By virtue of section 149(1)(b) proceedings could be taken for six years as against four years limitation as provided under section 149(1)(a) as income chargeable to tax for relevant year which had escaped assessment was more than one lakh rupees — Dr. AV Sreekumar vs. Commissioner of Income Tax [2018] 253 Taxman 428 (Kerala)

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