Validity of notice u/s 153A was challenged on the ground that there was no search at premises of the firm and in order to issue notice under S. 153A(1) there must be initiation of Search in case of notice is sustainable. Mere search authorisation is not sufficient. Dismissing the petition the Court held that, there is clear distinction between search authorisation and conduct of the search, in sub section (1) of S.153A, therefore, the legislature has advisably used the expression ‘Where a search is initiated under S.132’. On facts once the AO passes final order it will be always be open to challenge under the Act. Accordingly the writ petition was dismissed.