Dismissing the appeal of the revenue the Court held that the first appellate authority had recorded a clear finding of fact that as per panchanama drawn on 15^th September, 1998, the search which was carried out in terms of authorization dated 14^th September, 1998 was fully executed. After 15^th September, 1998 there was no search or seizure. On 13^th October, 1998 a prohibitary order was passed under Section 132(3) regarding the computer CPU of the respondent/assessee which was revoked on 14^th December, 1998. The first appellate authority had rightly held that passing of prohibitory order and revocation thereof were wholly irrelevant for the purpose of determining limitation under Section 158BE. Tribunal had considered the submission of the Revenue regarding Explanation 2 to Section 158BE but did not accept the same and rightly so. Finding returned by the first appellate authority as affirmed by the Tribunal is a finding of fact and we do not find any element of perversity in such finding of fact. In the absence thereof, no question of law, much less any substantial question of law, can be said to arise therefrom there being concurrent findings of facts by the two lower appellate authorities.