Law:

Section:

section 132 of the income-tax act, 1961-search and seizure-general-on 25-11-1981, petitioner, an income-tax assessee, claimed to have handed over packet containing rs. 10 lakhs to p, manager of a bank, for purchasing special bearer bonds, 1991, on 1-12-1981-on same day, p deposited packet with bank and obtained safe deposit receipt from it-on 30-11-1981 income-tax authorities seized said packet containing rs. 10 lakhs from bank under section 132(1), even though p told authorities that packet containing rs. 10 lakhs was left by petitioner with bank for specific purpose of utilising amount for purchase of special bearer bonds, 1991, on 1-12-1981-whether seizure of amount by tax authorities from bank was illegal and without jurisdiction-held, on facts, no-whether in view of fact that impugned money was deposited in safe custody for specific purpose of buying special bearer bonds, petitioner could invoke doctrine of promissory estoppel against government and ask for direction to government to reinvest same for purchase of bearer bonds-held, no Facts On 30-11-1981, under an authorisation issued by the Commissioner under section 132(1), the authorised officers entered the premises of the bank with a warrant of search and inspected the safe room of the bank and found a sealed brown paper packet containing Rs. 10 lakhs with a white label pasted thereon with the following note 'Safe deposit article deposited by P'. During the course of the search, the authorised officer elicited from P, the bank manager, that that packet containing Rs. 10 lakhs was left by the petitioner with P on 25-11-1981 at 11 a.m. for the specific purpose of utilising the said amount for the purchase of Special Bearer Bonds, 1991, on 1-12-1981. The petitioner had informed P that he was leaving Hyderabad that day and was not likely to return before 1-12-1981 and, hence, as soon as the sale of bearer bonds was commenced by the State Bank of India he should purchase the same. P, the bank manager, claimed to have deposited the packet with the bank on the same day and obtained a safe deposit receipt from the bank to the effect that one packet sealed with P's personal seal had been received for safe…

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