Validity of Search proceedings - Both the petitioners have admitted in their respective writ petitions...

Validity of Search proceedings - Both the petitioners have admitted in their respective writ petitions that they in fact did not file ITRs for certain AYs. Even this information, if available with the Department would have been sufficient for them to form a reason to believe for the purpose of Section 132(1)(c). In other words, it is not mandatory that in the present case there should have been summons under Section 131 of the Act for the Department to proceed to initiate action under Section 132 of the Act. - No relief granted to petitioner - HC .....

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