Search covered various premises and lockers, including certain Lockers with numbers 299, Locker 2070, and Locker 1320-Subsequent searches on 29/30-4-2021, revealed no seizures, and panchnamas were issued. Subsequently, an assessment order pertaining to assessment year 2015-16 was framed by ACIT on 31-3-2023. Principal Commissioner invoked section 263 and issued a notice on 24-8-2023, observing that assessment order passed by ACIT was erroneous and prejudicial to interest of revenue. Assessee contested, said notice by asserting that as per panchnamas dated 29-4-2021 and 30-4-2021 framed in respect of aforesaid lockers, no seizures were made and in absence of any seizure, search stood concluded on 2-3-2021, when first panchnamas were drawn up and therefore, period of limitation for passing an order under section 153A expired on 31-3-2022 and this delay of one year in passing reassessment orders could not be condoned.  It was held  that restraint and revocation orders pertaining to Locker 299 unequivocally established that Locker 299 underwent its initial search on 29-4-2021, even though it resulted in no recoveries and that date marked onset of limitation period prescribed under section 153B.  High Court held that search operation being an ongoing process that definitely concluded on 29-4-2021, when Locker 299 was inspected that rendered assessment under section 153A, which culminated on 31-3-2023, within time limit prescribed under section 153B.  On SLP it was noted that  order was passed without issuing a formal notice to respondent,Department or calling for a response from Department although standing counsel for Department was present in Court. Therefore, High Court having passed order without having benefit of response of respondent-Department, SLP filed by assessee was to be disposed of by reserving liberty to assessee herein to raise contentions regarding jurisdictional error vis-a-vis limitation period before appropriate authority despite impugned order passed against assessee.  (AY. 2015-16)