Reason to believe for search upheld despite procedural objections and CGST transition challenge.

Prior intelligence and earlier search operations in the same investigation provided sufficient prima facie material to support a search of the petitioner's premises, so the objection that there was no reason to believe failed. Alleged procedural irregularities, including the use of the word "resumed" and seizure of original title deeds, did not invalidate the search where bona fide action and nexus to the alleged evasion were otherwise shown. The challenge based on the coming into force of the Central Goods and Services Tax regime also failed because the search formed part of proceedings initiated before the new Act took effect. The writ petition was dismissed.

---

---

Issues: Whether the search conducted at the petitioner's premises was jurisdiction or illegal for want of reason to believe, alleged non-compliance with search procedure, and the coming into force of the Central Goods and Services Tax regime.

Analysis: The proceedings showed prior intelligence and earlier search operations in the same investigation, and the material placed before the Court disclosed a sufficient nexus between the petitioner's premises and the alleged evasion. The Court held that the existence of reason to believe could not be rejected merely because the petitioner disputed the relevance of the seized records or pointed to certain procedural lapses such as the use of the word "resumed" or the seizure of original title deeds. Such irregularities, even if assumed, did not invalidate a search otherwise supported by prima facie material and bona fide action. The Court also held that the search was part of proceedings initiated before the Central Goods and Services Tax Act, 2017 came into force and therefore was not vitiated on the ground of the new regime.

Conclusion: The challenge to the search failed and the writ petition was dismissed.

---