Allowing the appeal of the Revenue the Court held that the detailed satisfaction note showed multiple entries in the account books of SS and others. The manner in which SS, who was either in Siliguri or in Goa, contacted the assessee in Ahmedabad for a loan of Rs. 10 crores did not appear to be a normal transaction. Subsequent repayment of the mortgage with interest and income being reflected in the relevant AY appeared to be steps taken by the assessee to give the colour of genuineness but the stand of the Department that such entry was an accommodation entry was required to be found out and the web of entries required to be unravelled including the trail of the money paid by the assessee. The Department had asserted that the accommodation entry was a common modus operandi to bring unaccounted black money into the books for a brief period. The investment of Rs. 10 crores for a short period was not for earning interest income as it was repaid in the same AY. The Department intended to investigate the fund trail of the money paid by the assessee. Such belief was not whimsical. The Department was specific. There were no allegations of mala fides against the officers of the Department. In view of the detailed reasons recorded in the satisfaction note including the investment made by the assessee for a brief period and that investment being alleged to be an accommodation entry, it could not be said to be such as not to satisfy the prerequisite conditions of section 132(1) of the Act. It was not unreasonable for the Department to apprehend that the assessee would not respond to the summons before the Assessing Officer in the State of West Bengal. It was also alleged that such summons would lead to disclosure of information collected by the Department against SS and his group. The belief drawn by the Department that the assessee would not produce or cause to be produced any books of account or other documents which would be useful or relevant to the proceedings under the Act was not based upon conjecture but on a bona fide opinion framed in the ordinary conduct of the affairs by the assessee generally. The Department wished to find the source from which the loan of Rs. 10 crores was advanced to a total stranger, unconnected with either the affairs of the assessee or any other link, to justify how a person in Ahmedabad had advanced Rs. 10 crores to a company situated at Kolkata in West Bengal for the purpose of investment in Goa. The Department may fail or succeed but that would not be a reason to interfere with the search and seizure operations at the threshold, denying an opportunity to the Department to unravel the mystery surrounding the investment made by the assessee. Clauses (b) and (c) of section 132(1) were satisfied. The Department would be at liberty to proceed against the assessee in accordance with law. (AY. 2017-18)