Where search at the assessee’s premises was conducted on different dates pursuant to the original authorization, the limitation for completion of block assessment had to be computed from the date on which the search proceedings were finally concluded and not from the date of first search. A restraint or prohibitory order under section 132(3) cannot be equated with “deemed seizure” contemplated under the second proviso to section 132(1), as such order is passed only when immediate seizure is impracticable and does not amount to seizure itself. Since the search initiated on 8-12-1999 continued on subsequent dates and was ultimately concluded only on 2-3-2000 upon lifting of the prohibitory order, the search could not be treated as completed on the earlier dates. Accordingly, limitation under section 158BE(1)(b) was to be reckoned from 2-3-2000 and the block assessment order dated 28-3-2002 was within time. The distinction between restraint order and deemed seizure reiterated and decision in VLS Finance Ltd. v. CIT (SC) applied. Matter remitted to Tribunal for decision on merits. (BP : 1990-91 to 8-12-1999).