( 1 ) ON February 2, 1973 an officer of the Income-Tax Department duly authorised by the Commissioner of Income-Tax, Delhi (Central) under section 132 (1) of the Incometax Act, 1961 (hereinafter called "the Act)" carried out search of the residence of the petitioner. He sealed a steel almirah in the premises. A list of articles found in the almirah was prepared and they were put in two packets and sealed. During the search he also found keys of two lockers of the Delhi Safe Deposite Company. One of these lockers No. 2046 stood in the name of the petitioner and the other, bearing No. 1799, was in the joint names of the petitioner and her daughter Mrs. Mala Singh. Both these lockers were scaled. On February 7, 1973 the lockers were opened in the presence of the petitioner and inventories of their contents were prepared and orders under sub-section (3) of section 132 were issued to the Bank restraining it from parting with or allowing the contents to be removed. Sub-section (5) of section 132 of the Act provides that the Incometax officer, after affording a reasonable opportunity to the person concerned of being heard and making such enquiry as may be prescribed, sh