The petitioners/assessees comprising of assessee-company, its directors and relations were a leading manufacturer of forging and engineering products required in the automobile industry. The assessees were regularly assessed to income-tax and wealth tax and no penalty under section 271(1)(c) had ever been levied upon assessees for any concealment or furnishing inaccurate particulars of income. A search was conducted at the business premises of assessee-company as well as at residential premises of other assessees, pursuant to an authorization issued by Director of Income-tax (Investigation) under section 132(1).The assessees submitted that by the initiation of search proceedings and also the manner in which the proceedings were conducted, they were apprehensive that the revenue would, without jurisdiction or authority of law, proceed against assessees to make assessments and/or reassessments of past six assessment years in the case of all petitioners and raise huge demands by way of tax, interest and penalties, which would cause hardship and prejudice to the assessees. It was assessees case that authorizations issued against them were unconstitutional, ultra vires, invalid, without jurisdiction, etc., and were liable to be quashed and set aside on the ground that the conditions specified under section 132(1)(a) to (c) are not satisfied. Before the Court the Revenue produced   the contents of the file of the department given in a sealed envelope by respondents has been read. Having considered the contents thereof, it is opined that it does not disclose any information which would lead the Authorities to have a reason to believe that any of the contingencies as contemplated by section 132(1)(a) to (c) are satisfied. The reasons recorded, only indicates a mere pretence. The material considered is irrelevant and unrelated. For the sake of maintaining the confidentiality, the reasons recorded in the file are not being discussed, suffice to say that the information noted therein is extremely general in nature. The reasons forming part of the satisfaction note have to satisfy the judicial conscience. One is not satisfied. The satisfaction note does not indicate at all the process of formation of reasonable belief. The adequacy or sufficiency of the information has not been questioned.  Court held that  apart, the note also does not contain anything altogether regarding any reason to believe, on account of which, there is total non-compliance with the requirements as contemplated by section 132(1) which vitiates the search and seizure. It does not fulfil the jurisdictional pre-conditions specified in section 132. Accordingly the Court held that  the action of respondents taken under section 132(1) cannot be to sustained The same is, therefore, quashed and set aside. As a result, all consequent actions and notices cannot be sustained and accordingly quashed and set aside. Court also held observed that as regards the averments in the affidavit in reply, the views expressed in  Balkrushma Gopalrao Buty v. Principal Director (Investigation) [Writ Petition No. 1729 of 2024, dated 23-4-2024] is agreeable that respondents cannot rely upon what has been unearthed pursuant to the search and seizure action as the information giving a reason to believe as contemplated under section 132(1) must be prior to such seizure. Court also clarified that order quashing the search proceedings does not preclude the Revenue from taking any such proceedings as they may be advised and to utlise the information or material in such proceedings as they may be so advised and to utilise the information or material in such proceeding against the assesse as is permissible in law.  Followed Balkrushma Gopalrao Buty v. Principal Director (Investigation) [Writ Petition No. 1729 of 2024, dated 23-4-2024](Bom)(HC)  referred, PDIT(Inv))  v. Llajibhai Kanjibhai Mandalia (2022) 288 Taxman 361/ 446 ITR 18 (SC), DGIT v. Spacewood  Furnishers (P) Ltd (2015) 232 Taxman 131/ 12 SCC 179  (AY. 2008-09)