A search and seizure under section 132 was conducted at the petitioners’ premises from 1 November 2023 to 3 November 2023 based on five transactions dated 20 December 2019, 21 December 2019, 17 August 2020, 25 August 2020 and 2 February 2022, where B was the purchaser of immovable property jointly with one Anil Sapra. These transactions had been disclosed in returns filed by B for the relevant years; consequently, there was no fresh material to justify a search under section 132. The Court held that the Department’s satisfaction note did not disclose any information leading to a reason to believe the contingencies in section 132(1)(a)(c) were met. The note failed to show any prior reason to believes a requirement that cannot be supplied retrospectively by what was found in lockers during the search. No prior notice or sufficient recorded reasons existed; therefore, the search and seizure were vitiated and were quashed. All consequential actions were also set aside, but the Department was given liberty to take action lawfully using the seized material if permissible.