In all these writ petitions, the narrow question agitated by the assessees is that assessment order made on 22.12.2017 under Section 153A read with Section 254 of Income Tax Act, 1961 (hereinafter „the Act’) for Assessment Year 2005-06 and subsequent years (up-to 2012-13) covered by search assessment, were barred and therefore, needs to be quashed. Allowing the  petition the Court held that ;it is quite evident from the decision in  CIT v. Odeon Builders  Pvt Ltd( 2017) 393 ITR  27 (FB) (Delhi)(HC)  that limitation begins (for any purpose under the Act) from the point of time when the departmental representative receives the copy of a decision or an order of the ITAT. The evidence on record in this case clearly establishes that the concerned DR (a Commissioner ranking officer) nominated by the revenue received a copy of the ITAT order dated 30.03.2016. The Starting point of limitation therefore was 31.03.2016. The next question is whether the non-obstante clause under Section 153 of the Act, which prescribes a specific period of limitation to complete a search assessment for the block period concerned, could override the general period of limitation.  During the relevant period when the assessment was completed, the period prescribed was nine months (on account of substitution carried out by the amendment). The special provision under Section 153B of the Act in the opinion of the Court carves out a special period of limitation without which search/block assessments would not be completed. The entire provisions under Chapter XIV relating to block assessment, have been termed by the Supreme Court to be a complete code. At the same time, a specific period of limitation prescribed is for completion of original block assessments for the search and seizure proceedings. The period for issuing notice and completion of block assessment for all the concerned years (7 years) is within two years. Now, in the opinion of the Court, to apply that general two years limitation, the block reassessment proceeding after remand is not a feasible proposition. In the judgments in Nokia India (P) Ltd. v. Dy.CIT (2017) 85 Taxmann.com 291 (Del.) as well as CIT v. Bhan Textile P. Ltd., (2008) 300 ITR 176 (Del.) are relevant authorities.In PCIT v. PPC Business and Products P. Ltd., (2017) 398 ITR 71 (Del.), this Court emphasized the need to initiate the proceedings wherever the revenue wished to proceed further in case of search and seizure within the time and underlined that in case the assessments are not initiated and completed within the time prescribed, the valuable right accrues to the assessee. The general provision of two years, in the opinion of the Court, has been provided with one important objective i.e. to cater to a specific situation where upon search and seizure operation, if new material is found, already completed assessments are revisited. Had Parliament not prescribed such a specific period of limitation, possibly, the assessee’s concern would have successfully urged that search and seizure proceedings would be confined only to the concerned year in which the search operation took place. It was proposed to tide over such situation. The only provision that prescribed a period of limitation in respect of remands at the relevant time at least in this case is Section 153(2A). In that sense, that period of limitation prescribed for completion of remand (nine months) constituted a special provision, which applies to every class of remand regardless whether they originate from assessments/re-assessments/revisions or search and seizure assessments. In these circumstances, completion of the assessment proceedings for the block period by the impugned order dated 22.12.2017 was clearly beyond the period of limitation. As noticed earlier, the last date by which the remand order could have been worked out validly was 31.12.2016. Accordingly the impugned order pursuant to the remand dated 22.12.2017 and all consequential orders and actions are hereby quashed. (W.P.(C) 4304/2018 & CM APPL.16759/2018, dt. 01.10.2018) ( AY. 2005 -06  to 2012- 13)