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2019 (7) TMI 1502 - DELHI HIGH COURTDisclosure of reasons to belief for conducting search u/s 132 - impact of insertion of Explanation to Section 132(1) by the FA, 2017 with retrospective effect - assessment u/s 153A - Revenue points out that while discussing the satisfaction note in the judgment [2018 (12) TMI 292 - DELHI HIGH COURT] and that the reproduction of the said ‘reason to believe’ recorded in the satisfaction note, may not be consistent with the above Explanation - HELD THAT:- It appears that the purport of the said Explanation is against a disclosure of what may be contained in a file to any person, authority or Appellate Tribunal. However, the High Court is precluded from seeing the note or discussing it in a judgment where there is a challenge to the search itself. It is clarified that although in paragraph 16 of the judgment, a portion of the note may have been reproduced, this will not be treated as a precedent for a Petitioner in a future case challenging a search to insist that the contents of the note should be reproduced in the order/judgment.
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