ITO vs. Seth Brothers 1969 (74) ITR 836 (SC)

Section 132 does not confer any arbitrary authority upon the Revenue Officers. The Commissioner or the Director of Inspection must have, in consequence of information, reason to believe that the statutory conditions for the exercise of the power to order search exist. He must record reasons for the belief and he must issue an authorisation in favour of a designated officer to search the premises and exercise the powers set out therein.

The condition for entry into and making search of any building or

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