Judicial review of search authorisation is limited to relevant material, applied mind, and rational nexus, not reappraisal of sufficiency.

Judicial review of a search authorisation under the Income-tax Act is limited to whether the authorising authority had relevant material, applied its mind, and formed a belief with a rational nexus to that material. On the facts, information from the FIU unit, bank transaction data and secret enquiries indicated large cash deposits, immediate issuance of demand drafts and cheques, and a pattern suggestive of accommodation entries and unaccounted transactions. The satisfaction note showed consideration of this material and a live link to the belief that the statutory conditions were met. The Court held that it could not reassess the sufficiency of the material, and the challenge to the search and seizure failed.

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Issues: Whether the search and seizure action taken under section 132 of the Income-tax Act, 1961 was material, without recorded reasons to believe, or otherwise illegal so as to warrant interference under article 226 of the Constitution of India.

Analysis: The record showed that the authorising authority acted on information received from the FIU unit, bank transaction data, and secret enquiries disclosing large cash deposits, immediate issue of demand drafts and cheques, and a pattern suggestive of accommodation entries and unaccounted transactions. The satisfaction note reflected consideration of this material and a live link between the information and the belief that the statutory conditions under section 132(1) were met. In judicial review, the Court could examine whether relevant material existed and whether the belief had a rational nexus with that material, but could not sit in appeal over the sufficiency of the material. The facts placed before the Court negatived the plea of mere suspicion, absence of application of mind, or mala fides.

Conclusion: The search authorisation under section 132 was held to be supported by material and reason to believe, and the challenge to the search and seizure failed.

Ratio Decidendi: Judicial review of a search under section 132 is confined to examining the existence of relevant material, application of mind, and rational nexus for the belief formed by the authorising authority, and the Court will not reappraise the sufficiency of that material.

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