(1.) Petitioner No.1 is a partnership firm while Petitioner No.2 is one of its partners.
(2.) It appears that on 15th/16th October, 1971 the Income Tax Authorities [particularly the Director of Inspection (Investigation)] conducted a search and seizure operation in the residential as well as business premises of the partnership firm and one of its partners, namely, Shri Puran Mal. The search and seizure operation was conducted in Delhi, Hathras and Bombay. As a result of the operation, 114 silver bars lying deposited with the Laxmi Commercial Bank in Delhi and Punjab National Bank in Delhi were seized by the Respondents along with books of accounts and other documents.
(3.) It was submitted by learned counsel for the Petitioners that the silver bars belonged to Puran Mal (individual) and not to the partnership firm. We need not go into this controversy since Puran Mal (Individual) is not before us.