Dismissing the petition the Court held that though when an item or cash, was produced before a criminal court the Department could not issue a notice under section 132A to the court in question, once the item was produced before the court in connection with any criminal case registered by the police or any other law enforcement agency, an application for release or for giving custody of it to the Department could only be in accordance with the provisions of the Code of Criminal Procedure and specifically section 451 of the 1973 Code thereof. That did not take away the fact that the Department had initiated proceedings under section 132A to requisition the amount from the police station. Therefore, the case was covered by the first proviso to section 148A and the procedure prescribed under the provisions of section 148A need not be complied with before issuing the notices under section 148 for the assessment years 2020-21 to 2023-24. (AY.2020-21 to 2023-24)