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Issues: Whether assessment orders were vitiated because they were based on documents and account books seized under an allegedly unconstitutional or illegal search and seizure.
Analysis: The challenge rested on the premise that once the search and seizure were unlawful, the materials so obtained could not be used in assessment. The Court rejected that premise and held that illegality in the manner of obtaining documents does not by itself affect their admissibility. Admissibility depends on relevancy, not on the means by which the evidence was procured, and the Court found no constitutional provision or other legal bar in the Indian context that excluded such evidence merely because the seizure was unauthorized or ultra vires.
Conclusion: The assessment orders were not vitiated by reliance on the seized account books and records, and the challenge failed.
Ratio Decidendi: Evidence relevant to the issue in hand is admissible notwithstanding that it was obtained by improper or illegal means, and an assessment is not invalid merely because it relies on such material.