(1.) The case of Smt. Shanti Hora, the appellant, is that she carries on business of discounting of "purchies" and postdated cheques. The appellant, an assessee under the Income-tax Act, 1961, is regularly assessed to income-tax by the Income-tax Officer, "G" Ward, Dist. SSC-VIII, Calcutta, respondent No. 6 herein.
(2.) On November 7, 1985, the officers of the. Income-tax Department raided premises No. 52, Surya Nagar, Agra, in the State of U.P., under a search authorisation issued by the Commissioner of Income-tax, Agra, respondent No. 3 herein, and conducted a search under Section 132(1) of the Income-tax Act, 1961. The said premises No. 52, Surya Nagar, Agra, is owned by Ashok Kumar Hora, a son of the appellant.
(3.) At the time of the search, the appellant was residing in the ground floor of the said premises. The officers of the Income-tax Department after the search seized "purchies" valued at Rs. 8,30,877 and post-dated cheques for Rs. 1,53,254 as recorded in a seizure list from the ground floor of the said premises where the appellant was staying.