Seizure of immovable property under section 132 was without jurisdiction, as that provision covers movable assets only.

Section 132 of the Income-tax Act authorises seizure of movable assets such as money, bullion, jewellery or other valuable article or thing, not immovable property. The Court distinguished provisional attachment under section 281B as the statutory route for dealing with immovable property where lawfully warranted. Because the proceedings were initiated under section 132, the seizure of immovable property exceeded the scope of that provision and was without jurisdiction. The seizure was therefore invalid and liable to be quashed, and the petitioner succeeded.

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Issues: Whether immovable property could be seized in proceedings initiated under section 132 of the Income-tax Act, 1961, and whether such seizure was without jurisdiction.

Analysis: Section 132 contemplates seizure in respect of movable assets such as money, bullion, jewellery or other valuable article or thing. The departmental contention that immovable property could be dealt with was noted, but the Court distinguished provisional attachment under section 281B, which is the provision enabling attachment of immovable property where lawfully warranted. Since the proceedings in the present case were admittedly initiated under section 132, the seizure of immovable property travelled beyond the statutory scope of that provision and was without jurisdiction.

Conclusion: The seizure of immovable property under section 132 was invalid and liable to be quashed; the petitioner succeeded.

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