Requisition under Section 132A stands where recorded satisfaction is based on information and need not be disclosed.

Section 132A permits requisition of assets where the income-tax authority, on information in its possession, records reason to believe that statutory conditions are satisfied. The recorded satisfaction and underlying material form part of the authority's internal decision-making, and the Explanation to Section 132A means they are not required to be disclosed to any person, authority or tribunal. The court relied on the statutory text and later Supreme Court authority to reject a claimed right to obtain the recorded reasons. The challenge to the requisition notice therefore failed, and non-disclosure of the reasons did not invalidate the action.

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Issues: Whether the requisition action under Section 132A of the Income-tax Act, 1961 was jurisdiction for want of disclosed material and recorded satisfaction, and whether the recorded reasons had to be furnished to the petitioners.

Analysis: Section 132A empowers the prescribed income-tax authority to requisition assets where, in consequence of information in its possession, it has reason to believe that the statutory conditions are met. The recorded satisfaction and the basis of information are part of the authority's internal decision-making and, by virtue of the Explanation to Section 132A, are not required to be disclosed to any person, authority, or tribunal. The authorities relied on the statutory text and the later Supreme Court view that such reasons need not be revealed, and distinguished the decisions cited by the petitioners as turning on different facts and not laying down any right to disclosure of the material forming the basis of requisition.

Conclusion: The challenge to the requisition notice failed, and the petitioners were not entitled to disclosure of the recorded reasons or to invalidation of the action under Section 132A.

Ratio Decidendi: In proceedings under Section 132A of the Income-tax Act, 1961, the authority's recorded reason to believe, founded on information in its possession, is not required to be disclosed and cannot be compelled to be furnished merely because the requisitioned asset is claimed by the person from whose possession it was seized.

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