Om Prakash, J.

1. The petitioner carried on a business in manufacture and sale of carpets as sole proprietor of the concern, Sriram Carpet Industries, Gopiganj, district Varanasi. A search and seizure operation was conducted on July 22, 23, 1987, at the principal place of business, Gopiganj, district Varanasi, at the shopping complex, Maldahia, and at the residential premises, D-64/143, Shastri Nagar, Sigra, Varanasi, of the petitioner. During the search and seizure operation, gold ornaments, silver ornaments, cash, etc., were seized under Section 132(1) of the Income-tax Act, 1961 (briefly "the Act") and a restraint order was passed under Section 132(3) of the Act, for want of verification in respect of the following assets :

Rs.

(i) Stock of woollen yarn, etc. 7,00,855

(ii) Stock of 85 carpets 5,58,603

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12,59,458

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2. Thereafter, the Income-tax Officer, Bhadohi, Varanasi, passed an order under Section 132(5) determining the total tax liability for the assessment years 1981-82, 1983-84, 1984-85, 1987-88 and 19