Expired freezing order challenge became infructuous, while inspection of seized records was directed for assessment proceedings.

A time-bound freezing order became infructuous once it expired by efflux of time, so the challenge to the bank account freeze no longer survived for adjudication. The petitioner was also entitled to inspect seized books of account and other documents for use in assessment proceedings, and the respondents stated that inspection would be granted on approach to the concerned officer. The petition was therefore disposed of with the freeze challenge treated as infructuous and with facilitation of inspection of the seized records.

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Issues: (i) Whether the challenge to the freezing of the bank account survived after the freezing order had expired. (ii) Whether the petitioner was entitled to inspection of the books of account and other documents seized during the search.

Issue (i): Whether the challenge to the freezing of the bank account survived after the freezing order had expired.

Analysis: The freezing order had operated only for a limited period and had already expired by efflux of time. Once the order ceased to operate, the challenge to the freezing of the account no longer survived for adjudication.

Conclusion: The challenge to the freezing of the bank account was infructuous and did not survive.

Issue (ii): Whether the petitioner was entitled to inspection of the books of account and other documents seized during the search.

Analysis: The petitioner sought inspection of the seized records for the purpose of responding in assessment proceedings. The respondents agreed that on the petitioner's representative approaching the concerned officer, inspection of the seized books and documents would be granted.

Conclusion: The petitioner was entitled to inspection of the seized books of account and other documents.

Final Conclusion: The petition was disposed of with the challenge to the freezing order having become infructuous and with a direction to facilitate inspection of the seized records.

Ratio Decidendi: A challenge to a time-bound freezing order becomes infructuous upon expiry, while inspection of seized records may be directed where it is needed for participation in pending proceedings.

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