(PER : HONOURABLE MR. JUSTICE A.S. SUPEHIA)
1. RULE. Learned Senior Standing Counsel Mr. Varun Patel waives
service of notice of rule on behalf of the respondent – Department. Since a
pure question of law is raised in the writ petition, the same was heard
extensively and is finally decided today by this present judgment and
order.
2. The brief facts giving rise to the filing of the writ petition are as
under:
2.1. A search and seizure operation under Section 132 of the Act of the
Income Tax Act, 1961 (for short “the Act”) was initiated on Sambhaav, Nila
NEUTRAL CITATION
C/SCA/9447/2023 JUDGMENT DATED: 23/02/2026
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and its key associations on 08.09.2021.



