Sec. 142(2A) & 158BE of Income Tax Act, 1961— Search and seizure—The time period stipulated by the AO for completion of special audit would commence only from the date when the assessee is communicated and receives the order and not the date of the order and the outer time-limit of 180 days specified in the proviso has been fixed with reference to the date on which the direction under sub-s. (2A) of s. 142 is received by the assessee and not from the date of the passing of the order. Reason given by the learned Tribunal in its order for holding the block assessment order passed on 13th Nov., 2000 to be within limitation on the ground that though as per argument of the assessee, the limitation would have expired on 11th Nov., 2000 which was a Saturday and the following day i.e., 12th Nov., 2000 being a Sunday, the order passed on 13th Nov., 2000 would be saved, because of the said two non-working days is not the correct reasoning, but the order passed on 13th Nov., 2000 was even otherwise within limitation as per the clear provisions of the Act which excluded the period of a special audit from the date of issuance of directions on 17th April, 2000 till 31st July, 2000 = 105 days which extended the limitation for completing the assessment upto 13th Nov., 2000 per se, therefore, even though the reason assigned by the Tribunal for holding the assessment to be within limitation is incorrect, but the conclusion arrived at by the learned Tribunal is legally sustainable conclusion as per the interpretation of the provisions of the Act — A.P. Shanmugaraj vs. DY. CIT [2020] 313 CTR 225 (MAD)