Search authorisation cannot be challenged in block assessment proceedings; validity must be pursued separately before the High Court.

In a block assessment appeal, the Assessing Officer cannot examine the legality of a search under section 132 or test whether the warrant of authorisation was validly issued. The Appellate Tribunal is equally barred from enlarging appellate review to call for the satisfaction note or warrant for that purpose, because the authorization of search is an administrative act outside assessment proceedings. Any challenge to the validity of the search must be pursued in independent proceedings before the High Court. The Tribunal's contrary view was set aside.

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Issues: Whether, in an appeal against a block assessment, the Assessing Officer or the Appellate Tribunal can examine the validity of the search under section 132 of the Income-tax Act, 1961, including by calling for the satisfaction note and warrant of authorisation.

Analysis: The initiation of search by issuance of a warrant of authorisation is an administrative function and is not itself the subject-matter of assessment proceedings. The Assessing Officer is required to complete the block assessment on the basis of the search material and the statutory framework, but cannot sit in judgment over the legality of the authorization or examine whether the competent authority had sufficient reasons to believe for issuing the warrant. For the same reason, the Appellate Tribunal, while hearing an appeal against the assessment, cannot enlarge the scope of appellate review to adjudicate upon the validity of the search by summoning the warrant or the satisfaction note. Any challenge to the legality of the search lies in independent proceedings before the High Court.

Conclusion: The question is answered in the negative. Neither the Assessing Officer nor the Appellate Tribunal can examine the validity of the search or call for the satisfaction note for that purpose; the finding of the Tribunal to the contrary is set aside.

Ratio Decidendi: The legality of the search authorization under section 132 is a matter outside the scope of block assessment appellate proceedings, and challenges to such authorization must be pursued independently, not within the assessment appeal.

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