JUDGMENT

1. The petitioners by way of this writ petition have prayed that the respondents be directed to release the attached stock-in-hand belonging to petitioner Nos.1 and 2 respectively and quash and set aside the wrongful action taken against the petitioners.

2. Brief facts to be noticed are that on 24.02.2020 the petitioner No.3-Kantivardhan Pradeep Choraria was intercepted and searched at Jaipur Airport during his journey from Mumbai to Jaipur while he was carrying jewellery and diamonds, by the Income Tax Authorities. The said jewellery found in his possession was seized in terms of Section 132 of the Income Tax Act, 1961 (hereinafter referred to as "the Act of 1961").

3. The petitioner No.1 and 2 who are the Proprietor of M/s Daha Dimon and M/s Maha Pragya Jewellers and are brother-in-law have submitted that apart from jewellery two challans were seized which had been issued by M/s Maha Pragya Jewellers and M/s Daha Dimon in relation to jewellery and the entire jewellery was part of stock-in-trade and stock-in-hand with petitioner No.3 who was employer of petitioner No.2.

4. Learned counsel for the petitioners submits that the challan bearing No.1050 in the name of M/s Maha Pra