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Court Rules Invalid Conversion of Survey to Search Without Pending Proceedings u/s 131(1) of Income Tax Act.
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....Validity of Search and seizure - conversion of survey in search - provisions of Section 131(1) could be invoked only if some proceedings were pending - nowhere any satisfaction recorded either of noncooperation or a suspicion that income has been concealed by the petitioner warranting resort to the process of search and seizure - the impugned action of the respondents is quashed....