Allowing the petition the Court held that the authority must have information in his possession on the basis of which a reasonable belief can be founded that the person concerned has omitted or failed to produce the books of accounts or other documents for production of which summons or notice has been issued or such person will not produce such books of accounts or other documents even if summons of notice is issued to him, or such person is in possession of any money, bullion or other valuable articles which represents either wholly or partly income or property which has not been or would not be disclosed has to be the basic fulcrum on which, the exercise of the power under S 132 would revolve. Such reasons may have to be placed before the High Court in the event of a challenge to formation of the belief of the competent authority in which event the Court would be entitled to examine the reasons for formation of the belief, though not the sufficie or adequacy thereof. Court held that recorded reason does not disclose any information. Search action is quashed and set aside. Relied on DGIT (Inv). v. Spacewood Furnishers (P) Ltd. (2015) 277 CTR 322/ 119 DTR 201 (SC), (2015) 12 SCC 179, PDIT (Inv.) v. Laljibhai Kanjibhai Mandalia (2022) 327 CTR 353 / 215 DTR 417 (SC)
Balkrushna Gopalrao Buty v. PDI (Inv) (2024) 340 CTR 75 / 238 DTR 145 (Bom)(HC)
S. 132 : Search and seizure-Validity-Reason to believe-Recorded reason does not disclose any information-Search action is under quashed and set aside.[R. 112(2),Art. 226]