On information that a bank account maintained by CPI(M) was neither linked with PAN nor disclosed in the returns filed, and that despite repeated requests from the bank since 2010 to furnish KYC documents and link PAN there was refusal by the operators of the account, the Department gathered further material showing substantial transactions including withdrawal of Rs. 1 crore on 2-2-2024 with a balance of Rs. 4.81 crores. On the basis of such material, the Director General of Income-tax (Investigation) recorded satisfaction and authorised search and seizure under S. 132. The petitioner challenged the action under Art. 226. The High Court held that invocation of S. 132 is a drastic step but permissible where there is prima facie material indicating undisclosed income. On perusal of the satisfaction note and approval order, it was evident that detailed reasons were recorded and approval granted after due application of mind. There was no material to establish mala fides. In the circumstances, the “reason to believe” could not be said to be perverse or legally untenable and the search action did not warrant interference (relying on Director General of IT (Inv.) v. Spacewood Furnishers (P) Ltd. (2015) 277 CTR (SC) 322). However, as regards the prohibitory order issued under S. 132(3) on 5-4-2024 directing the bank not to operate specified accounts, in view of S. 132(8A) such order cannot remain in force beyond 60 days. Since the statutory period had expired, the prohibitory order ceased to operate by force of law and no further declaration was required.