Held that the date of search was on July 5, 2018, and the limitation for completion of assessment for the assessment years 2013-14 to 2018-19 being 18 months under section 153B commencing from April 1, 2019, the end of the financial year when the last of the search authorisations was executed ended by September 30, 2021, i. e., 18 months or 549 days. On the date of grant of stay first by the court, i. e., on December 18, 2019, time of 288 days remained. After the dismissal of the writ petitions on March 17, 2021, appeals were filed and a stay was granted for a period of 53 days from April 15, 2021 to June 7, 2021. The orders of assessment dated January 28, 2022 relied upon the extension under the 2020 Act of one year from September 30, 2020 to September 30, 2021. The last date for completion of assessment as prescribed by section 153B being within a period of twenty-one months from the end of the financial year in which the last of the authorisations for search under section 132 or for requisition under section 132A was executed fell on September 30, 2020 which was within the limitation as stipulated in the 2020 Act and extended to September 30, 2021 by virtue of subsequent notifications. The extension, by taking benefit of the period of interim protection would follow only thereafter and the date stood extended by 16 months and 24 days to April 20, 2023. Therefore, the orders of assessment passed on January 29, 2022 were within prescribed time. The assessment orders passed under section 143(3) read with section 153A and the penalty orders under sections 271(1)(c) and 271B dated January 27, 2022 for the assessment years 2013-14 to 2018-19 were confirmed. The assessee was permitted to file statutory appeals on the merits and such appeals, if filed within the time prescribed by the court should be entertained by the appellate authority without reference to limitation but ensuring compliance with all other statutory requirements.   For the assessment years 2011-12, 2012-13 and 2019-20 since no writ petitions were filed by the assessee the question of any period available thereafter to the Department did not arise. Therefore, applying the limitation prescribed under section 153B, the date for statutory time limit for assessment expired on September 30, 2020, though extended up to September 30, 2021 by virtue of the 2020 Act and subsequent extensions. Hence, the last date for completion of assessments for the assessment year 2011-12, 2012-13 and 2019-20 being September 30, 2021, the assessment orders dated January 29, 22, were barred by limitation. That clause (xi) of the Explanation to section 153B inserted with effect from April 1, 2021 being a substantive provision related to exclusion of the period taken for handing over seized material to the Assessing Officer operated prospectively. Hence, the benefit of the exclusion under that clause was not available to the Department. That therefore, the notices under section 153A, the assessment orders under section 143(3) read with section 153A dated January 28, 2022 and the penalty orders under sections 271(1)(c) and 271B dated January 27, 2022 for the assessment years 2011-12, 2012-13 and 2019-20 were set aside.(AY.2011-12 to 2019-20)