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The HC dismissed the petition and upheld searches and seizures conducted under s.132 of the Act, holding the satisfaction note and approval by the DGIT established bona fide "reasons to believe" that income chargeable to tax had escaped assessment and that the petitioners would possess valuables disproportionate to known income. The Court held the three clauses of s.132(1) are disjunctive, so prior service of summons was not a prerequisite, and that formation of opinion under s.132 is an administrative act subject to limited judicial review confined to mala fides or absence of any real reasons. No persuasive evidence of malice or collateral purpose was shown, so interference was refused and the petition dismissed.
The HC dismissed the petition and upheld searches and seizures conducted under s.132 of the Act, holding the satisfaction note and approval by the DGIT established bona fide "reasons to believe" that income chargeable to tax had escaped assessment and that the petitioners would possess valuables disproportionate to known income. The Court held the three clauses of s.132(1) are disjunctive, so prior service of summons was not a prerequisite, and that formation of opinion under s.132 is an administrative act subject to limited judicial review confined to mala fides or absence of any real reasons. No persuasive evidence of malice or collateral purpose was shown, so interference was refused and the petition dismissed.
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