No books of account and documents were seized on 6-8-2020. It is also stated that the search commenced on 6-8-2020 on 11.00 AM and closed on 6-8-2020 at 2.00 PM. Further from the Panchnama where the parties offered for their personal search before the commencement of the search, was declined by the search party. Therefore, effectively no search was conducted on 6-8-2020 as per the Panchnama, dated 6-8-2020. In the absence of any seizure on 6-8-2020 by the search party it can only be considered for the purpose of removal of the restraint order and not as continuation of the search proceedings under the same authorization. Prohibitory order passed by the search party u/s. 132(3) by placing certain loose sheets cannot be considered as impracticable for seizure which requires a restraint order u/s. 132(3) of the Act. Hence, the period of limitation for the purpose of passing the assessment order commences from 31-1-2020 and should have been completed on or before 31-3-2021 which was further extended by Taxation and Other Laws Amendment (TOLA) to 30thSeptember, 2021. Therefore, in the present case, the assessment order ought to have been passed on or before 30-9-2021 wherein it was passed on 31-3-2022. Accordingly barred by limitation. (AY. 2012-13 to 2020-21)