S.132(1) – Warrant of authorisation is person specific and not location specific.

A search under section 132(1) has to be “person specific”. The authority authorising search has to have information in his possession in respect of a person and such a person should be specifically named in search warrant. CIT v. Smt. Umlesh Goel [2016] 387 ITR 575 (Raj).

The warrant of authorisation is person specific and states the places where search is required to be conducted qua such person. Such search may be at the office premises, residential premises or even at the premises of a third person, depending on where the competent authority has reason to suspect that books of account, other documents, money, bullion, jewellery or other valuable article or thing are kept. The contention based on rule 112 of the Rules that search is location specific does not merit acceptance. On a bare reading of rule 112 as a whole, there is nothing therein to indicate that search is location specific. Zinzuwadia and Sons v. DCIT [2019] 419 ITR 169 (Guj).