A search and seizure action was carried out at Assessee’s premises under section 132(1) of the Act. Block assessment order was passed. Penalty has also been levied under section 158BFA and prosecution proceeding has been initiated on basis of such block assessment order and a complaint filed before Court of Additional Chief-Metropolitan Magistrate for offences allegedly committed under section276C and 277 read with section 278B.  Assessee objected to passing of block assessment order by filing an additional ground in appeal filed by it before CIT(A) urged that jurisdictional pre-conditions in section 132(1) viz., clauses (a) to (c) thereof had not been fulfilled. Additional ground did not find favour with CIT(A). On appeal the Tribunal directed the Revenue to produce the records containing satisfaction recorded before issue of authorisation of the search warrant under section 132 (1) of the Act. The Revenue did not comply with the direction of the Tribunal. The Revenue filed writ petition seeking writ of certiorari for quashing  and setting aside the interim order passed by the Tribunal  directing the Revenue to produce the record containing the satisfaction note. The Revenue Contended that  Tribunal is not empowered to look in to the said matter hence the direction is invalid. The Court issued rule in the writ petition of the Revenue. The assessee also filed writ petition  challenging the validity of the search action  and quashing and setting aside the consequent block assessment block assessment order, penalty order and the complaint/prosecution  filed before the Magistrate Court. High Court directed the Revenue to produce satisfaction note.  The Revenue Could not produce sataisfaction note. Allowing the petition the Court held that  it is settled law that if no reason was ascribed for search and seizure action taken under Section 132 it would be illegal. Exercise of power under Section 132 is a serious invasion upon rights, privacy and freedom of tax-payer. Courts have held that this power must be exercised strictly in accordance with law and only for purposes for which law authorizes it to be exercise. Courts, after scrutiny, can decide on correctness of opinion formed by Income Tax Officer where action of officer issuing authorization or of Designated officer is challenged, the Officer concerned must satisfy Court about regularity of his action. If action is maliciously taken or power under section is exercised for a collateral purpose, it is liable to be struck down by Court. If conditions for exercise of power are not satisfied proceeding is liable to be quashed. Courts have held that it is only at stage of commencement of assessment proceedings after completion of search and seizure, if any, that requisite material may have to be disclosed to assessee. Though it is settled law that while sufficiency or otherwise of information cannot be examined by court in writ jurisdiction, existence of information and its relevance to formation of belief is open to judicial scrutiny because it is foundation of condition precedent for exercise of a serious power of search of a private property or person, to prevent violation of privacy of a citizen. It is also a settled law that court could examine whether reasons for belief have a rational connection or relevant bearing to formation of belief and search warrant could not be issued merely with a view to making a roving or fishing enquiry. Reasons will have to be placed before High Court in event of a challenge to formation of belief of competent authority in which event Court would be entitled to examine reasons for formation of belief, though not sufficiency or adequacy thereof. In other words, Court will examine whether reasons recorded are actuated by malafides or on a mere pretence and that no extraneous or irrelevant material has been considered. Such reasons forming part of satisfaction note are to satisfy judicial conscience of Court. Since satisfaction note which formed very basis for issuance and authorisation of search warrant under section 132(1) has not been made available in spite of a specific direction given by Tribunal way back on 17.06.2002 and repeated by this Court on 30.06.2023 an adverse inference needs to be drawn in respect of same especially having regard to circumstances set out here in before. Since, Revenue has failed to produce satisfaction note search action under section 132(1) and, consequently, block assessment order passed under section 158BC, order levying penalty under section 158BFA and Criminal Case is quashed. Court also observed that  the order does not preclude the Revenue from taking any such proceedings as they may be so advised and to utilise the information or material in such proceedings against the assessee as is permissible in law. Referred, PDIT (Inv) v.Laljibhai Khamjibhai Mandalia ( 2022) 327 CTR 353/ 215 DTR 417/ 140 taxmann.com 282/288 Taxman 361 (SC)/[2022] 446 ITR 18 ( SC)