Dismissing the appeal of the assessee the Court held that the proceedings commenced on March 16, 2000. There were a number of documents seized on that day which definitely would have taken up the entire day on which the search was conducted. The seizure had to be made on a cursory verification and a prima facie satisfaction being entered into of the need to seize them. A panchnama was drawn up and the other documents which the authorised officer wished to examine were placed in an almirah and it was issued with a restraint order under section 132(3). The seizure made of the documents which had been issued with a restraint order under section 132(3) could not be said to be the last panchnama. The last panchnama was drawn up on April 4, 2000. The assessment order passed on April 24, 2002 was not barred by limitation.(ITA No. 191 of 2012, dt. 07-01-2019)