The Assessee challenged the notices issued by the Revenue for inspection of jewelry seized during search operations and kept in sealed packages, contending that the reasons and information which prompted the inspection ought to have been supplied to the Assessee before the inspection was conducted. The PCIT had initiated proceedings under section 263 and sought inspection of the seized assets as part of that inquiry. The Court dismissed the writ petition and decided in favour of the Revenue and held that under rule 112(13), the power to reopen a sealed package is not predicated on any information in the possession of the Revenue or any “reason to believe” that might trigger an inspection. Such power can be exercised even in the absence of any information, provided the same is required for any of the purposes of the Act. There is no requirement in the Rules or in any provision of the Act that any information or reason based on which the requirement for reopening the sealed package arose must be communicated to the person from whose custody the contents were seized. All that is required to be communicated is a reasonable notice to be present. The Assessee’s participation in the inspection is only to ensure transparency of the process and to negate any apprehension of tampering. Inspection of a seized article does not constitute an invasive act like search and does not intrude into private space. Since the inspection was sought for the purpose of pending section 263 proceedings, and the PCIT is empowered to make such inquiry as he deems necessary, the notice could not be said to be in violation of rule 112(13). The writ petition was dismissed. (AY 2023-24)