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As per case facts, a search and seizure operation led to the seizure of assets, for which the Petitioner filed an Income Tax Return. Despite initial assessment and the Petitioner's
...explanation of asset sources, the Assessing Officer's order was partly accepted. Subsequently, the Principal Commissioner of Income Tax initiated revision proceedings, deeming the assessment erroneous and prejudicial to revenue, and issued notices for inspection of the seized assets. The Petitioner challenged these notices in the High Court, arguing a lack of statutory basis, specific purpose, and the non-disclosure of information prompting the inspection, especially given the ongoing appellate proceedings. The question arose whether the revenue authorities were obligated to provide the specific information and reasons for inspecting already seized and sealed assets, and whether such inspection notices were validly issued for "any of the purposes of the Act." Finally, the High Court ruled that the power to inspect seized articles for "any of the purposes of the Act" does not require specific information or "reason to believe" as a precondition, unlike search operations. It affirmed the Principal Commissioner of Income Tax's authority to make necessary inquiries under Section 263 and that the inspection notices, connected to a pending revision proceeding, were valid and not arbitrary, requiring only reasonable notice to the Petitioner for presence.
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