Allowing the petition the Court held that   the issuance of the notice under section 131(1A) after conducting of the search operation under section 132 was illegal and without jurisdiction and contrary to the provision which was very clear and there was no ambiguity. Even if there was an ambiguity the benefit of it must go the assessee. The Legislature having clearly laid down the manner in which the notice under section 131(1A) was to be issued, it had to be mandatorily followed. Any manner other than what was provided in the provision was necessarily forbidden. There could not have been any material that could be a reason to suspect that any income had been concealed or likely to be concealed by the assessee. Held that since the Principal Director (Investigation) and the Deputy Director (Investigation) had stated that the search and seizure action under section 132 was conducted on the basis of the authorisation issued by the Principal Director (Investigation), Guwahati and that during the post search investigation, the Deputy Director (Investigation), Dibrugarh had issued the notices under section 131(1A), it was evident that the search operation under section 132 had been carried out without issuance of notice under section 131(1A) but merely on the basis of the authorization. Therefore, the search conducted under section 132 and the subsequent notices under section 131(1A) were illegal and without jurisdiction.  That the Department had not placed any materials whatsoever to indicate that the assessing authority had any materials on the basis of which he had reasons to suspect that the assessee had concealed or was likely to conceal any income. The very fact that the Department had issued notices under section 131(1A) after the search and seizure operation under section 132 was conducted, showed that there was neither any reasons to suspect nor materials before the Assessing Officer on the basis of which search operation could have been conducted under section 132. Hence, the two essential conditions being absent before the search was conducted, it was without jurisdiction. The authorization issued for the search, the consequent search and seizure under section 132 and the notices issued under section 131(1A) were quashed and set aside. Taxing statutes are to be interpreted strictly and the assessee cannot be taxed by inference or by analogy. In case of any ambiguity in the taxing provision, the benefit of it should go to the taxpayer.