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“incriminating material”

Search & SeizureSection 153ASection 153A8,981 judgments

The decision most relied on for incriminating material is CIT v. Kabul Chawla (380 ITR 573), cited in 3,235 judgments on BharatTax.

Leading authorities on incriminating material

CIT v. Kabul Chawla
380 ITR 573 · 2016 · High Court
3,235
citing judgments

In a search assessment under Section 153A, additions can only be made for completed or non-abated assessment years if incriminating material relevant to those years is found during the search, although notice under Section 153A(1) is mandatorily issued for six assessment years preceding the search.

Pr. CIT v. Abhisar Buildwell (P.) Ltd.
149 Taxmann.com 399 · 2023 · Supreme Court
2,379
citing judgments

An assessment under section 153A is without jurisdiction if there is an absence of incriminating material for an unabated assessment year.

CIT v. Sinhgad Technical Education Society
397 ITR 344 · 2017 · Supreme Court
1,589
citing judgments

For assessments under Section 153C, a notice is legally unsustainable if there is no incriminating material correlated to the specific assessment years for which reassessment is sought.

Pr. CIT v. Meeta Gutgutia
395 ITR 526 · 2017 · High Court
1,226
citing judgments

In search assessments under Section 153A, additions to income are permissible only if incriminating material is found during the search; in the absence of such material, completed assessments cannot be disturbed. A statement recorded under Section 132(4) and later retracted may not, on its own, constitute sufficient incriminating evidence for making additions.

All Cargo Global Logistics Ltd. v. DCIT
137 ITD 287 · 2012 · ITAT
907
citing judgments

In non-abated assessments, the Assessing Officer can make additions under section 153A based on books of accounts or documents found during a search but not produced during the original assessment, provided such material is incriminating.

PCIT v. Best Infrastructure (India) (P.) Ltd.
397 ITR 82 · 2017 · High Court
786
citing judgments

A statement recorded under Section 132(4) of the Income Tax Act, 1961, does not by itself constitute incriminating material for making additions to income.

CIT v. RRJ Securities Ltd.
380 ITR 612 · 2016 · High Court
689
citing judgments

Completed assessments can be interfered with under Section 153A or 153C only on the basis of incriminating material unearthed during the search, necessitating a direct correlation between the discovered material and the power to assess or reopen concluded assessments.

Pr. CIT v. Saumya Constructions (P.)Ltd.
387 ITR 529 · 2016 · High Court
670
citing judgments

Assessments under Section 153A cannot be sustained without any incriminating material found during the search that substantiates the additions. This principle applies even to completed assessments where no additional income is disclosed.

Judgments citing incriminating material

Deputy Commissioner of Income Tax, Central Circle, Panaji vs. M/S Mohit Ispat Ltd., Kundaim

Appeal of the Revenue is PARTLY ALLOWED in aforestated terms

ITA 9/PAN/2020[2016-17]Status: DisposedITAT Panaji13 Oct 2026AY 2016-17

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliassessment Years: 2016-17 Dy. Commissioner Of Income Tax, Central Circle, Panaji, Goa. . . . . . . . Appellant V/S M/S Mohit Ispat Limited 339/340, Kundaim Industrial Estate, Goa-403115 Pan: Aaccm8154E . . . . . . . Respondent Represented Assessee By: Mr Shriniwas Naik & Narchiva Lotlikar [‘Ld. Ar’] Revenue By: Mr Naveen Kumar [‘Ld. Dr’] Date Of Conclusive Hearing : 04/02/2026 Date Of Pronouncement : 27/02/2026 Order Per G. D. Padmahshali; This Appeal Of The Revenue Instituted U/S 253(2) Of The Income-Tax Act, 1961 [‘The Act’] Challenges Order Dt. 04/10/2019 Passed U/S 250 Of The Act By The Commissioner Of Income Tax Appeals-2, Panaji Goa [‘Ld. Cit(A)’] Which In Turn Sprung From Order Of Assessment Dt. 30/12/2017 Passed U/S 143(3) Of The Act By Acit, Central Circle, Panaji Goa [‘Ld. Ao’] Anent To Assessment Year 2016-17.[‘Ay’]

For Appellant: Mr Shriniwas Naik & Narchiva Lotlikar [‘Ld. AR’]For Respondent: Mr Naveen Kumar [‘Ld. DR’]
Section 132Section 133ASection 139(1)Section 143(3)Section 246ASection 250Section 253Section 253(2)

survey proceedings u/s 133A of the Act simultaneously was also conducted at three manufacturing facilities of the assessee company, wherein certain incriminating material were found & seized. Pursuant thereto the case of the assessee subjected for compulsory scrutiny vide notice dt. 20/09/2017 143(2) of the Act and consequential assessment ... scraps etc., as imputed from the ITAT-Panaji Page 3 of 44 ACIT Vs M/s Mohit Ispat Limited ITA No. 009/PAN/2020 AY: 2016-17 incriminating materials found at the residential search premises of the director u/s 132 of the Act and (ii) ₹1,25,53,820/- unaccounted sales found

ACIT, Central Circle-2(3), Pune vs. Mantra Properties, Varanasi

In the result, the appeal filed by the Revenue is allowed

ITA 2116/PUN/2024[2017-18]Status: DisposedITAT Pune23 Sept 2026AY 2017-18

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2017-18

For Appellant: NoneFor Respondent: Shri Ramnath P Murkunde
Section 143(3)Section 148Section 269SSection 271DSection 274

basis of concrete evidences. This contention of the assessee is not acceptable as the penalty has been initiated on the basis of incriminating material found during search action in the case of Shri Sachin Nahar who has confirmed the fact that cash loan was provided to Shri Satish Gupta ... levied mere on the basis of statement of third party, however in the instant case, the penalty has been initiated on the basis of Incriminating material corroborated by the statement recorded u/s 132(4) of the I.T. Act. Therefore, decision of the above mentioned both the cases are not applicable

DCIT, New Delhi vs. I Energizer Holdings Ltd., New Delhi

In the result, the Cross Objection of the assessee is allowed and consequently the appeal of the revenue is liable to be dismissed

ITA 4654/DEL/2015[2012-13]Status: DisposedITAT Delhi07 Sept 2026AY 2012-13

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

For Respondent: Sh.Vizay B. Vasanta, CIT-DR &
Section 139Section 143(2)Section 144Section 147Section 148Section 149Section 151Section 153Section 153ASection 153C

707/2014, decided on 28th August, 2015 has held that completed assessments could only be interfered with by the AO on the basis of any incriminating material unearthed during the course of the search or requisition of the documents. In absence of any incriminating material, the AO does not have ... seized material. Obviously an assessment has to be made under this Section only on the basis of seized material." v. In absence of any incriminating material, the completed assessment can be reiterated and the abated assessment or reassessment can be made. The word 'assess' in Section 153 A is relatable

Upkar Mani, Delhi vs. ACIT CC-8, Jhandewalan

In the result, the appeal of the assessee is dismissed

ITA 3022/DEL/2023[2018-19]Status: DisposedITAT Delhi02 Sept 2026AY 2018-19

Bench: Ms. Madhumita Roy & Shri Brajesh Kumar Singh[Assessment Year 2018-19]

Section 132Section 153CSection 153DSection 250Section 69A

Page 95-96 of Annexure A-12 belonging to Sh. Upkar Mani was found and seized. On perusal of the satisfaction note and incriminating material received from the Assessing Officer of the searched person, satisfaction was recorded on 13.05.2021 by the DCIT, Central Circle-06, New Delhi, as the Assessing ... satisfaction note dated 13.05.2021 in the case of the assessee recorded by the Assessing Officer on the perusal of the satisfaction note and incriminating material received from the AO of the searched person i.e. in the case of Navneet Dawar & others group (DOS-03.01.2018) as the Assessing Officer of Shri

Revelation Unique Retail and Marketing Private Limited, Delhi vs. Assistant Commissioner of Income Tax, Central Circle-3, Delhi

In the result, the appeal filed by the assessee is allowed

ITA 1036/DEL/2025[2020-21]Status: DisposedITAT Delhi19 Aug 2026AY 2020-21

Bench: Shri Vimal Kumarshri Sanjay Awasthl

For Appellant: Sh. Pranshu Goel, CA & Aditya Gupta, AdvFor Respondent: Sh. Robin Rawal, CIT- DR
Section 115BSection 127Section 132Section 142(1)Section 153Section 153CSection 234Section 234BSection 250Section 272A(1)(d)

void ab initio; 3 That on the facts and circumstances of the case no addition can be made in the absence of any incriminating material found on record; 4. That on the facts and circumstances of the case and in law, Ld. CIT(A) grossly erred in sustaining the order

Rakesh H Mehta HUF, Mumbai vs. ACIT, CC-1(2), Pune

In the result, all the three appeals of the assessee are dismissed

ITA 1733/PUN/2024[2019-20]Status: DisposedITAT Pune15 Jul 2026AY 2019-20

Bench: Dr.Manish Borad & Shri Vinay Bhamore

For Appellant: NoneFor Respondent: Shri Arvind Desai
Section 132Section 132(4)Section 142(1)Section 250

action u/s.132 of the Act was conducted in the BVG Group of cases on 06.11.2019 in which the assessee was also covered and certain incriminating materials were impounded. Statutory notices were issued to the asssessee to which the assessee made compliance. Based on the seized material and information furnished ... that the ld. AO erred in making the alleged addition as the assessment has attained finality as on the date of search and no incriminating material in relation to commission income was seized. It was further contended that ld. AO has not provided the copy of statements given by Mr.Madhuchandra

Rakesh H Mehta HUF, Mumbai vs. ACIT, CC-1(2), Pune

In the result, all the three appeals of the assessee are dismissed

ITA 1732/PUN/2024[2019-20]Status: DisposedITAT Pune15 Jul 2026AY 2019-20

Bench: Dr.Manish Borad & Shri Vinay Bhamore

For Appellant: NoneFor Respondent: Shri Arvind Desai
Section 132Section 132(4)Section 142(1)Section 250

action u/s.132 of the Act was conducted in the BVG Group of cases on 06.11.2019 in which the assessee was also covered and certain incriminating materials were impounded. Statutory notices were issued to the asssessee to which the assessee made compliance. Based on the seized material and information furnished ... that the ld. AO erred in making the alleged addition as the assessment has attained finality as on the date of search and no incriminating material in relation to commission income was seized. It was further contended that ld. AO has not provided the copy of statements given by Mr.Madhuchandra

Rakesh H Mehta HUF, Mumbai vs. ACIT, CC-1(2), Pune

In the result, all the three appeals of the assessee are dismissed

ITA 1731/PUN/2024[2018-19]Status: DisposedITAT Pune15 Jul 2026AY 2018-19

Bench: Dr.Manish Borad & Shri Vinay Bhamore

For Appellant: NoneFor Respondent: Shri Arvind Desai
Section 132Section 132(4)Section 142(1)Section 250

action u/s.132 of the Act was conducted in the BVG Group of cases on 06.11.2019 in which the assessee was also covered and certain incriminating materials were impounded. Statutory notices were issued to the asssessee to which the assessee made compliance. Based on the seized material and information furnished ... that the ld. AO erred in making the alleged addition as the assessment has attained finality as on the date of search and no incriminating material in relation to commission income was seized. It was further contended that ld. AO has not provided the copy of statements given by Mr.Madhuchandra

Pawan Kumar Gupta, Gurgaon vs. Income Tax Officer-3(3) Bijnore, Bijnore

In the result, the appeal of assessee is allowed for statistical purposes

ITA 1355/DEL/2024[2017-18]Status: DisposedITAT Delhi20 Apr 2026AY 2017-18

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishra

Section 132Section 147Section 148Section 151Section 151(2)Section 153C

133A of the Act were carried out at various premises of Sweta & Oriental Group on 27.11.2019. During the course of intrusive operations, certain incriminating material were seized/impounded which showed that Shri Pawan Kumar Gupta along with his wife; Mrs. Prachi Gupta, had booked a flat and had paid cash ... taken by the Ld. AR is that the information entailing reopening of the case under section 148 of the Act has emanated from the incriminating material (wherein the name of the assessee along with his wife is mentioned having paid the sum of Rs.34,41,000/- during the relevant year

Himanshu Daksheshkumar Katwala, Khambhat Anand vs. Income Tax Officer, Ward-1(3)(1), Petlad

In the result, the appeal of the assessee is allowed

ITA 199/AHD/2026[2017-2018]Status: DisposedITAT Ahmedabad09 Apr 2026AY 2017-2018

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri Hardik J Raval & Vivek D Rao, ARsFor Respondent: Shri Girish Parihar, Sr. DR
Section 115BSection 132Section 143(3)Section 147Section 69A

cash, bullion, jewellery or valuable article was found in possession of the appellant. 6. The addition is unsustainable as it is made without any incriminating material, documentary evidence, statement, bank trail or seized material linking the appellant with any alleged accommodation entry. 7. The authorities erred in relying upon alleged

Ambey Enterprises, Delhi vs. Assessing Officer, Delhi

In the result, the appeal of assessee is allowed for statistical purposes

ITA 5505/DEL/2025[2017-18]Status: DisposedITAT Delhi09 Apr 2026AY 2017-18

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarambey Enterprises Vs. Assessing Officer 30/54 A 1St Floor Gali Ward 58(1) No.8, Vishwas Nagar Delhi Shahdara, Delhi 110032 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Abdfa 0570D Appellant .. Respondent

For Appellant: NoneFor Respondent: Ms. Harpreet Kaur Hansra, Sr. DR
Section 133(6)Section 142(1)Section 144Section 250Section 68Section 69A

facts and in the circumstances of the case and in law, Ld. AO materially erred in making impugned additions without pinpointing any sort of incriminating material or any unaccounted asset corresponding to the income assessed. 7. That on the facts and in the circumstances of the case

Kiran Wati, New Delhi vs. DCIT, Central Circle, Noida

In the result, the application for condonation of delay of 135 days in filing appeal and appeal filed by the assessee are allowed

ITA 362/DEL/2019[2011-12]Status: DisposedITAT Delhi09 Apr 2026AY 2011-12

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarsmt. Kiran Wati, Vs. Dcit 2473/13, Goverdhan Central Circle Bihari Colony, Shahdara, Noida New Delhi 110032 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Ahnpk 8472 A Appellant .. Respondent

For Appellant: NoneFor Respondent: Ms. Monika Singh, CIT-DR
Section 127Section 132Section 142(1)Section 143(2)Section 143(3)Section 153CSection 250(6)

facts and circumstances of the case, the learned assessing officer has erred both on facts and in law in making the addition as no incriminating material was found & seized, hence assessment order u/s 153C is invalid. 2. On the facts and circumstances of the case, the learned AO has erred ... days in filing appeal is condoned. 7. In additional ground, it is pleaded that Ld. AO erred in making addition without any incriminating material seized, so assessment u/s 153C is invalid. 8. Ld. Departmental Representative submitted that, Ld. AO had made addition on basis of cash deposit in Bank

Asstt. Commissioner of Income Tax, Central Circle-4, Jaipur vs. Gopal Prasad Gupta, Jaipur

The appeals of the revenue are dismissed

ITA 1765/JPR/2025[2013-14]Status: DisposedITAT Jaipur23 Mar 2026AY 2013-14

Bench: Shri Sanjay Garg & Shri Ratnesh Nandan Sahay

For Appellant: Sh. Rajnikant Bhatra, CAFor Respondent: Sh. Rajesh Ojha, CIT
Section 147Section 148Section 153CSection 250

Court's order dated 19.03.2024 in D.B. Civil Writ Petition No. 18363/2019 and several other linked petitions wherein wrongly held that once there is incriminating material seized or requisitioned belonging or relatable to the person other than on whom search was conducted, Section 153C is to be resorted to without ... Supra) is given as under:- “23. The reasons supplied in case in hand for initiation of proceedings under Section 147/148 are based on the incriminating material and documents including Pen Drives seized during the search carried out of the Manihar Group and the statements recorded during proceedings. From the information

Asstt. Commissioner of Income Tax, Central Circle-4, Jaipur vs. Gopal Prasad Gupta, Jaipur

The appeals of the revenue are dismissed

ITA 1764/JPR/2025[2016-17]Status: DisposedITAT Jaipur23 Mar 2026AY 2016-17

Bench: Shri Sanjay Garg & Shri Ratnesh Nandan Sahay

For Appellant: Sh. Rajnikant Bhatra, CAFor Respondent: Sh. Rajesh Ojha, CIT
Section 147Section 148Section 153CSection 250

Court's order dated 19.03.2024 in D.B. Civil Writ Petition No. 18363/2019 and several other linked petitions wherein wrongly held that once there is incriminating material seized or requisitioned belonging or relatable to the person other than on whom search was conducted, Section 153C is to be resorted to without ... Supra) is given as under:- “23. The reasons supplied in case in hand for initiation of proceedings under Section 147/148 are based on the incriminating material and documents including Pen Drives seized during the search carried out of the Manihar Group and the statements recorded during proceedings. From the information

S.S. Industries, Raipur vs. ACIT, Central Circle-1, Raipur

Appeals of the assessee are allowed for statistical purposes as above

ITA 817/RPR/2025[2020-21]Status: DisposedITAT Raipur20 Mar 2026AY 2020-21

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Avdhesh Kumar Mishra, Am आयकर अपील सं. / Ita Nos: 816 & 817/Rpr/2025 (िनधा"रण वष" Assessment Years: 2019-20 & 2020-21) S.S. Industries, Plot No.610, 611, Vs Assistant Commissioner Of Income- 620, 621, Urla Industrial Area, Village- Tax, Central Circle 1, Raipur, Central Accholi, Distt.-Raipur, C.G.-492003 Revenue Building, Raipur, C. G. Pan: Aclfs9015L (अपीलाथ"/Appellant) (""थ" / Respondent) : िनधा"रती की ओर से / Assessee By : None. राज" की ओर से / Revenue By : Shri Raghunath, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 17/03/2026 घोषणा की तारीख / Date Of : 20/03/2026 Pronouncement आदेश / O R D E R Per Avdhesh Kumar Mishra, Am:

For Appellant: NoneFor Respondent: Shri Raghunath, CIT-DR
Section 139Section 142(1)Section 143(2)Section 153CSection 250Section 250(6)Section 69C

unexplained expenditure u/s.69C of the Income-tax Act, 1961 without considering facts of the case in its entirety and without incriminating material. 5. The impugned order is bad in law and on facts. 6. The appellant reserves the right to addition, after or omit all or any of the grounds ... Income-tax Act, S.S. Industries, Raipur vs. ACIT, Central Circle-1, Raipur 1961 without considering facts of the case in its entirety and without incriminating material.” 4. The relevant facts giving rise to these appeals are that the Ld. Assessing Officer (‘AO’) initiated proceedings u/s 153C

S.S. Industries, Raipur vs. ACIT, Central Circle-1, Raipur

Appeals of the assessee are allowed for statistical purposes as above

ITA 816/RPR/2025[2019-20]Status: DisposedITAT Raipur20 Mar 2026AY 2019-20

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Avdhesh Kumar Mishra, Am आयकर अपील सं. / Ita Nos: 816 & 817/Rpr/2025 (िनधा"रण वष" Assessment Years: 2019-20 & 2020-21) S.S. Industries, Plot No.610, 611, Vs Assistant Commissioner Of Income- 620, 621, Urla Industrial Area, Village- Tax, Central Circle 1, Raipur, Central Accholi, Distt.-Raipur, C.G.-492003 Revenue Building, Raipur, C. G. Pan: Aclfs9015L (अपीलाथ"/Appellant) (""थ" / Respondent) : िनधा"रती की ओर से / Assessee By : None. राज" की ओर से / Revenue By : Shri Raghunath, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 17/03/2026 घोषणा की तारीख / Date Of : 20/03/2026 Pronouncement आदेश / O R D E R Per Avdhesh Kumar Mishra, Am:

For Appellant: NoneFor Respondent: Shri Raghunath, CIT-DR
Section 139Section 142(1)Section 143(2)Section 153CSection 250Section 250(6)Section 69C

unexplained expenditure u/s.69C of the Income-tax Act, 1961 without considering facts of the case in its entirety and without incriminating material. 5. The impugned order is bad in law and on facts. 6. The appellant reserves the right to addition, after or omit all or any of the grounds ... Income-tax Act, S.S. Industries, Raipur vs. ACIT, Central Circle-1, Raipur 1961 without considering facts of the case in its entirety and without incriminating material.” 4. The relevant facts giving rise to these appeals are that the Ld. Assessing Officer (‘AO’) initiated proceedings u/s 153C

Deputy Commissioner of Income Tax, Delhi vs. M/S Vestige Marketing Private Limited, Delhi

ITA 7844/DEL/2025[2024-25]Status: DisposedITAT Delhi20 Mar 2026AY 2024-25

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

For Appellant: Shri Amit Goel andFor Respondent: Ms. Monika Singh, CIT-DR
Section 132Section 133(6)Section 143(3)Section 147Section 37Section 37(1)Section 69A

provision of Section 132(4) of the Act in the context of discovering undisclosed income, explained that in cases where no unaccounted documents or incriminating material is found, the powers under Section 132(4) of the Act cannot be invoked. The relevant passage from the aforesaid judgment is quoted below ... able to find any unaccounted money, unaccounted bullion nor any other valuable articles or things, nor any unaccounted documents nor any such incriminating material either from the premises of the company or from the residential houses of the managing director _and_ other directors. In such a case, when the managing

Deputy Commissioner of Income Tax, Delhi vs. M/S Vestige Marketing Private Limited, Delhi

ITA 7843/DEL/2025[2023-24]Status: DisposedITAT Delhi20 Mar 2026AY 2023-24

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

For Appellant: Shri Amit Goel andFor Respondent: Ms. Monika Singh, CIT-DR
Section 132Section 133(6)Section 143(3)Section 147Section 201Section 37Section 37(1)Section 69A

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH 'F': NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER AND SHRI

Deputy Commissioner of Income Tax, Delhi vs. M/S Vestige Marketing Private Limited, Delhi

ITA 7842/DEL/2025[2022-23]Status: DisposedITAT Delhi20 Mar 2026AY 2022-23

Bench: Shri Before Shri Satbeer Singh Godarabefore Shri Before Shri Satbeer Singh Godarasatbeer Singh Godara & Satbeer Singh Godara & And & Shri Naveen Chandra Shri Naveen Chandra, , , Shri Naveen Chandra Shri Naveen Chandra

For Appellant: Shri Amit Goel and Shri Pranav Yadav, Advocate
Section 132Section 143(3)Section 147Section 37Section 37(1)Section 69A

provision of Section 132(4) of the Act in the context of discovering undisclosed income, explained that in cases where no unaccounted documents or incriminating material is found, the powers under Section 132(4) of the Act cannot be invoked. The relevant passage from the aforesaid judgment is quoted below ... things, nor any unaccounted documents valuable articles or things, nor any unaccounted documents valuable articles or things, nor any unaccounted documents nor any such incriminating material either from the premises of nor any such incriminating material either from the premises nor any such incriminating material either from the premises

Deputy Commissioner of Income Tax, Delhi vs. M/S Vestige Marketing Private Limited, Delhi

ITA 7841/DEL/2025[2021-22]Status: DisposedITAT Delhi20 Mar 2026AY 2021-22

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

Section 132Section 133(6)Section 143(3)Section 147Section 37Section 37(1)Section 69A

provision of Section 132(4) of the Act in the context of discovering undisclosed income, explained that in cases where no unaccounted documents or incriminating material is found, the powers under Section 132(4) of the Act cannot be invoked. The relevant passage from the aforesaid judgment is quoted below ... able to find any unaccounted money, unaccounted bullion nor any other valuable articles or things, nor any unaccounted documents nor any such incriminating material either from the premises of the company or from the residential houses of the managing director and other directors. In such a case, when the managing