Petitioner is a reputed Homoeo doctor with a homoeo clinic at Kottayam and is an assessee under the Income-tax Act being assessed by the second respondent. A search conducted by the first respondent in the residence and clinic of the petitioner at Kottayam on 30.12.1994 led to seizure of cash around Rs.6 lakhs. Indira Vikas Patras (IVP) for Rs. 6 lakhs and promissory note for the value of Rs.3 lakhs. Consequent on certain date collected during search in the petitioners premises the first respondent arranged search through his counter-parts in Baroda in the residence of two sons of the petitioner, namely, Indravadan R. Patel, and Jawaharlal patel on 4.1.1995, which led t6o seizure of IVPs of the value of Rs.66.7 lakhs and Rs.2.46 lakhs respectively. However, in view of admission by the petitioner and his sons in the course of search the IVPs seized from the petitioner’s sons were also treated as undeclared income of the petitioner and proceeded with. In fact, in the course of search, petitioner made a total disclosure of Rs.1,46,78,980/- for the financial years 1989-90 to 1994-95 under Section 132 (4) of the Income-tax Act. After conclusion of search, the first responden