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    <title>1970 (7) TMI 17 - GUJARAT High Court</title>
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    <description>Search and seizure provisions aimed at uncovering undisclosed income were upheld as constitutionally valid because they operated with recorded reasons, reviewable satisfaction, and post-seizure safeguards that made the restrictions proportionate to tax enforcement. By contrast, the fifteen-day time limit for issuing a show cause notice under rule 112A was treated as mandatory because it was integral to the statutory inquiry scheme under section 132(5), which required prompt commencement and fair opportunity before the ninety-day limit expired. A notice issued beyond that period was therefore without jurisdiction and invalid.</description>
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    <pubDate>Wed, 01 Jul 1970 00:00:00 +0530</pubDate>
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      <title>1970 (7) TMI 17 - GUJARAT High Court</title>
      <link>https://www.taxtmi.com/caselaws?id=8037</link>
      <description>Search and seizure provisions aimed at uncovering undisclosed income were upheld as constitutionally valid because they operated with recorded reasons, reviewable satisfaction, and post-seizure safeguards that made the restrictions proportionate to tax enforcement. By contrast, the fifteen-day time limit for issuing a show cause notice under rule 112A was treated as mandatory because it was integral to the statutory inquiry scheme under section 132(5), which required prompt commencement and fair opportunity before the ninety-day limit expired. A notice issued beyond that period was therefore without jurisdiction and invalid.</description>
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      <pubDate>Wed, 01 Jul 1970 00:00:00 +0530</pubDate>
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