S.132 – Change of address of assessee will not invalidate the search.

A plain reading of section 132 of the Act would disclose that when the competent authority has reason to believe that any person is in possession of any money, bullion, jewellery or other valuable article or thing and such money, bullion or jewellery or other valuable articles or other thing represents either wholly or partly, income or property which has not been or would not be disclosed for the purposes of the Act would partake of the characteristic of an undisclosed income or property, then, warrant of search would be issued authorising the officer indicated in sub-clause (A) or (B) to enter and search any building, place, vessel etc., are kept. The language or expression of sub-section (1) of section 132 is clear and unambiguous. The location of the premises is in relation to the satisfaction reached by the authorities mentioned therein and the authorised officer can search any place mentioned in the warrant including any other place where he suspects that the books of account belonging to the assessee are kept. Mere change of address of the assessee even being in the know of the Income-tax Department by itself would not vitiate or invalidate the search conducted under section 132 of the Act. Principal Commissioner of Income-tax v. Associated Mining Co. [2019] 417 ITR 420 (Kar).