High Court allowed writ petition challenging the validity of search action against the assessees holding that the information giving a reason to believe as contemplated under section 132(1) of the Income-tax Act, 1961, must be prior to such seizure, that the contents of the file of the Department given to the court in a sealed envelope did not disclose any information which would lead the authorities to have reason to believe that any of the contingencies as contemplated by section 132(1)(a) to (c) of the Act, were satisfied, that the material considered was irrelevant and unrelated, that no notice or summons had been issued to the assessees calling for any information from them at any prior point of time to form a reasonable belief that the assessee had omitted or failed to produce books of account or other documents for production of which summons or notice had been issued, or that such person would not produce such books of account or other documents even if summons or notice is issued to him, that the satisfaction note did not fulfil the jurisdictional preconditions specified in section 132 of the Act, and that therefore, the search proceedings were not legal. SLP of revenue dismissed.  However, the question of law was kept.