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Survey, Search & Seizure | 35 |(ii) Search operations shall be authorized only by the concerned DGIT(Inv.), who will be accountable for the action initiated by the officersworking under him. He should also ensure that all the work relatingto search & seizure, like post-search inquiries, preparation of appraisalreport and handing over of seized books of account, etc., should becompleted by the Investigation Wing within a period of 60 days fromthe date on which the last of the authorization for search was executed.(iii)DGIT (Inv.) is to ensure that officers of competence and provenintegrity are taken in the Investigation Wing. The Officers posted inthe Investigation Wing will be trained at NADT in a special course forwhich arrangements will be separately made- Vide Instruction No.7/2003, dt. 30-7-2003.Gems of judiciary1. It was held in Kalpana bazar v. CIT (1990) 186 ITR 617 (Ker) that It isnot the mandate of section 132 or any other provision in the Act that thereasonable belief recorded by the designated authority before issuingthe warrant of authorization must be disclosed to the assessee but samehas been recently distinguished by Allahabad High Court in M/s Md Overseas Ltd. v dGIT & Others, [2011] 198 TAXMAN 136(All.),where in it has been held that when assessee makes a prima facie caseagainst validity of search, Revenue is obliged to share informationrelating to ‘reasons to believe’ for authorizing search except the sourceof information.2. Space wood furnishers Pvt. Ltd. director General of Income Tax(Investigations) [2012] 340 ITR 0393 (bom) / 2011-TIOL-837-hC-MuM-IT.- High growth and high profit margins, which are the matterof record cannot be the basis for issuing search warrant.3. M/s jeeT CONSTRuCTION COMPANY Vs ACIT, IT[SS] AppealNo.26 (del) of 2011,2012-TIOL-11-ITAT-deL - Whether when Revenuesearches several persons, a combined satisfaction recorded can be saidto be legally valid for initiating action under Sec 158BD - YES, rulesITAT4. VISA Comtrade Limited v. union of India [2011] 338 ITR 343 (Ori)-The belief should not be based on some suspicion or doubt. Where theDepartment had not cross verified the entries in the current account inquestion with the regular books of account maintained by the assesseeand investigation on whether the money lying with the current accountwww.taxguru.in