R.V. Raveendran, J.—The appellant claims that he is a manufacturer of silver and gold articles carrying on business under the name and style of "Anitha Metal Works" and an assessee under the Income Tax Act, 1961 ("the Act", for short). He has maintained a locker bearing No. 139 having taken it on hire from Shaswathi Leasing Private Limited at B.V.K. Iyengar Road, Bangalore.

2. In pursuance of warrant issued under Section 132 of the Income Tax Act, 1961, in regard to the premises of Shaswathi Leasing Private Limited, a search was conducted on March 31, 1997, at the premises of the said Shaswathi Leasing Private Limited. It is stated that as the appellant was maintaining a locker, on request, he voluntarily opened the locker at the time of search conducted in the premises of Shaswathi Leasing Private Limited and the contents of the said locker were inventoried and sealed on March 31, 1997.

3. Thereafter, a search warrant under Section 132 of the Act was issued authorising search and seizure in regard to locker No. 139 maintained by the petitioner herein in the premises of Shaswathi Leasing Private Limited and in pursuance of the said warrant, the locker was again opened, sear