Income-Tax Officer vs Nurul Huda G. Aboobkar. on 4 March, 1995
19. Now, coming to the contention of the ld DR that sub-section (3) to section
132A has categorically placed requisition proceedings u/s 132A at par with search
proceedings u/s 132 and therefore, Explanation 5 applied as much as to section
132A as it does to section 132 of the Act and once reference is made to section 132
then the same is automatically deemed to include reference to section 132A also.
We find that similar contention has been advanced in case of ITO vs Nurul Huda
G. Aboobkar (supra) before the Bangalore Benches of the Tribunal and the
relevant findings of the Coordinate Bench read as under: