Illegal seizure does not bar relevant copies from revenue assessment when no exclusionary rule applies.

Illegally seized documents did not become unusable in revenue assessment merely because the seizure was unlawful. The Court held that admissibility depends on relevancy, not on the lawfulness of the source, and found no exclusionary rule in the Evidence Act, the Constitution, or the applicable sales tax law. Photostat copies of the seized material retained in court could therefore be relied on by the revenue for assessment purposes, and the request to prevent such use was rejected.

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Issues: Whether photostat copies of documents illegally seized and kept in a sealed cover could be used by the revenue in assessment proceedings.

Analysis: The seizure of the originals was treated as illegal and their return had already been directed. The remaining question was whether the department could nevertheless use copies retained by the court. The Court held that there was no distinction in principle between using illegally seized documents and using copies of them in revenue assessment, because the admissibility of such material depends on relevancy and not on the lawfulness of the source. The Evidence Act contains no prohibition against such use, and neither the Constitution nor the applicable sales tax law created an exclusionary rule barring reliance on the material.

Conclusion: The revenue was entitled to use the photostat copies retained in court for assessment purposes, and the request to forbid such use was rejected.

Final Conclusion: Illegally seized material does not become unusable in revenue assessment merely because the seizure was unlawful, and copies of such material may be used where they are relevant and otherwise admissible.

Ratio Decidendi: There is no rule excluding relevant evidence from revenue assessment proceedings merely because it was obtained by an illegal search or seizure.

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