In Brief
An employee of N.K. Jewellers was found carrying Rs. 30 lacs by railway police during a train search in 2000. Income tax authorities seized the cash and initiated assessment proceedings for the period 1991–2000, treating it as undisclosed income. The appellant claimed it was uncompleted business transaction proceeds. The Supreme Court dismissed the appeal, holding that the challenge to the validity of the search proceedings was raised too late and barred; further, the Finance Act 2017 amendment to Section 132A prevents disclosure of the 'reason to believe' underlying a search, precluding judicial review. The factual finding that the appellant's explanation was unreliable and the cash constituted concealed income was not demonstrably erroneous.
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