19. Sub-section (5) of S. 132 does not contemplate a different procedure in the matter of regular assessment. See Section 132A which shows that those who are found in possession of undisclosed income on a seizure are liable to be regularly assessed or reassessed. Sub-section (5) only contemplates a provisional summary enquiry with a view to determine how much of the seized wealth can be legitimately and reasonably retained to cover the tax liability already incurred. Regular assessment follows under the law in the same manner as in the case of tax evaders who are not found in possession of concealed income. The utmost that can be said is that by reason of the seizure the Government is in a position to secure its tax dues before the regular assessment is concluded. But that does not introduce any different procedure for the regular assessment of such an assessees income which remains the same for all tax evaders. In one set of cases the fiscal authorities make sure of recoveries, in the other, they are unable to do so - not because the provisions of Section 132 do not operate on them, but because action under that section by search and seizure is futile. Therefore, there is no subst