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e) Jayantilal Damjibhai Soni & Ors V Director of Investigation & Anr 291 CTR (Guj) 26 (Guj) "Search and seizure--Block assessment--Validity of notice under s, 158BC--Assessees are six co - owners of a cinema building called JRT given on lease to a partnership firm JST-- Record showed that on the day the satisfaction note was approved by Dy. Director of IT (Inv.) and further approved by Director of IT (Inv.), there was no proposal and no approval in relation to either the assessees in their individual capacity or as partners of JRT as. an entity--Subsequently, Asstt. Director of IT (Inv.) recorded a satisfaction note in relation to office premises of JRT/JST by merely repeating the language of s. 132 without recording any reasons--Warrant of authorisation actually issued in the name of "Partners of JRT/JST"--This showed that while recording satisfaction for issuance of warrant of authorisation the authority was not sure as to the premises of which persons were required to be searched--There was, thus, no material with the authority to even prima facie come to the conclusion that an entity by the name of JRT, a partnership firm, existed at the point of time when the search proceedings were initiated by issuance of warrant of authorisation--Thus, at no point of time, an entity named JRT, a partnership firm, was ever subjected to search proceedings under s. 132, and JRT not being a person searched, notice under s. 158BC served on JRT was invalid--Document unearthed during the course of earlier survey, being a draft document of proposed sale of JRT is of no avail as it is neither signed by the sellers nor purchasers--In the said document, the vendors, who are the six assessees are described as co-owners--Action of authority in issuing impugned notice under s. 158BC cannot, therefore, be sustained"