https://www.taxtmi.com/caselaws?id=371454 Validity of notice under Income-tax Act s.153A turned on whether a "search is initiated" u/s 132 in the noticee's case, since mere issuance of search authorisation is insufficient given the statutory distinction between authorisation and actual conduct of search. However, where search was in fact conducted at multiple premises connected with a partnership firm, and no provision prima facie confined search action to the firm's registered office, the HC held that the factual nexus and objections should be examined by the AO, consistent with SC guidance against writ interference at show-cause stage. The writ was disposed by relegating the assessee to the AO without quashing the notices, keeping all contentions open. en-us Thu, 29 Nov 2018 00:00:00 +0530 Wed, 24 Dec 2025 15:39:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=371454 Validity of notice under Income-tax Act s.153A turned on whether a "search is initiated" u/s 132 in the noticee's case, since mere issuance of search authorisation is insufficient given the statutory distinction between authorisation and actual conduct of search. However, where search was in fact conducted at multiple premises connected with a partnership firm, and no provision prima facie confined search action to the firm's registered office, the HC held that the factual nexus and objections should be examined by the AO, consistent with SC guidance against writ interference at show-cause stage. The writ was disposed by relegating the assessee to the AO without quashing the notices, keeping all contentions open. Case-Laws Income Tax Thu, 29 Nov 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=371454