During the execution of a search warrant dated March 13, 2001, the Income-tax authorities got information about a locker belonging to the assessee in a bank. Therefore on March 26, 2001, a second authorisation was issued for searching the locker and the search was executed on March 26, 2001 itself. Notice under section 158BC was issued for block assessment. The assessee filed his return and the assessment was completed in April, 2003. Similar assessment orders were passed in the case of other assessees. The assessees filed appeals challenging the assessment orders, inter alia, on the ground that the assessment was time barred, contending that the two-year period as prescribed under section 158BE(b) of the Act from the date of the panchnama drawn on March 26, 2001, came to an end by March, 2003 and the assessment order was passed in April, 2003. The Commissioner (Appeals) dismissed the appeals. However, the Tribunal held that the assessment orders were barred by limitation but the High Court held that as the last panchnama though related to search authorisation dated March 13, 2001 was executed on April 11, 2001, limitation of two years was to be computed from April 11, 2001 and the assessments were within time. On appeals dismissing the appeal the Court held that the  Limitation to be reckoned  from date of  last Panchnama and  not date of  last warrant of  authorisation.   (AY. Block period 1985-86 to 5-12-1995)