The assessee was a proprietorship concern engaged in wholesale trading of ready-made garments. A flying squad entered his business premises claiming knowledge about huge cash lying with the assessee which according to them was meant for use in elections for influencing voters in violation of the election laws and guidelines. No notice had been received by him in this regard and thus, the authority of the flying squad was unknown. The proprietor of the assessee handed over the cash which was a collection of payments received from different customers and meant for different purposes. The cash was not even counted by the flying squad, who simply collected the cash, prepared a seizure list and left the business premises. The Committee constituted under the guidelines of the Election Commission concluded that the seized cash had no connection with the election. Meanwhile the cash was requisitioned under a warrant of authorisation issued under section 132A of the Income-tax Act, 1961. On a writ the Court held that the proceeding was an outcome of a raid conducted under the guidelines of the Election Commission of India and the seizure was not a consequence of a raid made by the Income-tax authorities under section 132 of the Act, nor could any order be passed in purported exercise of jurisdiction under section 226(3) of the Act. Even otherwise, the seizure itself was without sanction of law which was apparent from the fact that no first information report or complaint was instituted as provided under clause 4 of the Guidelines nor was the case submitted to the court of competent jurisdiction within 24 hours nor did the Committee constituted under the Guidelines take any decision to order seizure of the cash, in the absence of any first information report/complaint instituted in terms of clause 16(i). The order of requisition was not valid.