JUDGMENT

SABYASACHI MUKHARJI, C.J.I. :— This is a special leave petition directed against the judgment and order of the High Court of Rajasthan, dated 18th July, 1989. The petitioner herein i.e. Smt. Kusum Lata Singhal carried on, at all relevant times, business under the name and style of M/s. Lata & Company and she claims to be an authorised stockist of Baba Brand Tobacco manufactured by M/s. Dharampal Premchand Ltd., New Delhi. Mr. R. K. Singhal is the husband of the petitioner. In the judgment under appeal, it has been stated that Mr. R. K. Singhal owns a house No. E-117, Shastri Nagar in Jaipur and the petitioner lived with her husband at all material times. Mr. Singhal was a partner in Lata Sales Centre and is said, to be a sub-dealer of M/ s. Lata & Company.

2. A search under Section 132 of the Income-tax Act, (hereinafter called the Act) was conducted at the said premises on 25/26th Nov. 1987. During the search, valuables and books of accounts were seized on 26th November, 1987, and a notice under rule 112A of the Income-tax Rules, 1962 (hereinafter referred to as the Rules) read with subsection (5) of Section 132 of the Act was issued to the petitioner by the Income-tax Off