Survey cannot be converted into search without recording satisfaction

Pawan Kumar Goel Vs Union of India (Punjab and Haryana HC)

Conversion of survey proceedings into search in absence of satisfaction recorded either of non-­cooperation or suspicion of escaped income was invalid

Conclusion: In case there was only a survey operation under section 131 and no proceedings were pending at that point of time in assessee’s case, exercising power of search under section 132 by income tax authorities without any satisfaction recorded either of non-­cooperation of assesse

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