Allowing the petition the court held that  failure to furnish the panchanama to the assessees was a violation of the principles of natural justice as it disabled them from having knowledge of the seized materials and the alleged incriminating materials relied upon by the Department. The Department either should not have relied on the statements recorded under section 132(4) and if they were relied upon, the Department should not have denied the opportunity to the assessee’s demand to cross examine the persons who gave the statements. The contention of the Department that since the statements recorded were of persons who were employees of the assessee and therefore the assessee could not seek cross-examination of them could not be accepted. The plea of alternative remedy which was also an effective one to undo the violations committed by the Department was unsustainable. Relied on Kishinchand Chellaram v. CIT (1980)  125 ITR 713 (SC). Court also held that   when the assessments had been framed only on the basis of the electronic records which were copies of excel sheet, excel work note book etc., failure to comply with section 65B of the Indian Evidence Act, 1872 rendered the document inadmissible in the eye of law. Relied on  Anvar P. v. V. P. K. Basheer (2014)  10 SCC 473 and Maharashtra Chess Association v. UOI  (2020)  13 SCC 285. Court set aside the assessment order. The Court also observed that the limitation if any would stand extended and would start afresh for completion of the fresh assessment proceedings. (AY.2013-14 to 2019-20)