J.S.Khehar, J.

1. Rajesh Mahajan (petitioner No. 1), Sangeeta Mahajan (petitioner No. 2, and wife of petitioner No. 1), Pranab Mahajan (petitioner No. 3, and son of petitioner No. 1) and Smt. Kamal Saroj (petitioner No. 4, and mother of petitioner No. 1) are stated to have partnership interests in Mahajan Exports (petitioner No. 5), Maspar (petitioner No. 6) and Anand Co. (petitioner No. 7).

2. Mahajan Exports, i.e., petitioner No. 5, is a partnership firm comprising petitioners Nos. 1 to 3. It is stated to be engaged in the business of manufacture and export of handloom products. Its factory a well as the head office are stated to be located at Panipat (although it is acknowledged that it has one small sales office at Delhi). Masper, i.e., petitioner No. 6, is a partnership firm comprising petitioners Nos. 1 and 2. It is also stated to be engaged in the business of manufacture and export of handloom products, its factory as well as head office are stated to be located at Panipat. Anand Co., i.e., petitioner No. 7, is a partnership firm comprising petitioners Nos. 1 and

3. It is stated to be engaged in carrying out trading activities in handloom products. Its business premises are stated to be located at Panipat. The facts narrated above have not been disputed in the written statement filed on behalf of the respondents.

4. All the petitioners were regularly assessed to income-tax at Panipat by the Assistant Commissioner of Income-tax, Panipat, as well as by the Income-tax Officers of Wards Nos. 1 and 4. From the facts depicted in the foregoing paragraph, it is apparent that petitioners Nos. 1 to 4 are individuals, being members of one family, whereas petitioners Nos. 5 to 7 are partnership concerns comprising petitioners Nos. 1 to 4. The books of account relating to the business activities of petitioners Nos. 5 to 7 are stated to be maintained and kept in the business premises of the three firms at Panipat itself. The factum of residence of the petitioners at Panipat, the location of their business premises at Panipat and the maintenance of books of account at Panipat, are also not disputed.

5. Rakesh Mahajan is the brother of Rajesh Mahajan (petitioner No. 1). Rakesh Mahajan along with his family members are stated to control Mahajan Overseas Ltd., which has its registered office at E-1 and E-2, South Extension, Part-11, New Delhi. Likewise, Rakesh Mahajan and his family members also control Mahajan Industries Private Ltd. and Pan Foods Ltd. The registered office of the latter two concerns being the same address as that of Mahajan Overseas Ltd. While Mahajan Overseas Ltd. and Mahajan Industries Pvt. Ltd. are engaged in the property business, Pan Foods Ltd. is engaged in the business of manufacture of food products such as jams/ketchups, etc. The aforesaid concerns which are controlled by Rakesh Mahajan and his family members are stated to be assessed to income-tax at Delhi, by the Deputy Commissioner of Income-tax, Central Circle-20, New Delhi. The aforesaid facts pertaining to the business concerns of Rakesh Mahajan and his family members have been drawn from the averments made in the writ petition. None of the aforesaid averments have been disputed in the written statement.

6. Search and seizure operations under Section 132 of the Income-tax Act, 1961 (hereinafter referred to as "the Act"), were conducted on August 29, 2000. The aforesaid search and seizure operations were conducted for detection of income-tax evasion. During the course of the said search and seizure operations, Mahajan House, Panipat, and business ventures of the concerns referred to above located at Industrial Area, Panipat, Mahajan House, E-1 and E-2, South Extension, Part-II, New Delhi, and B-81, Greater Kailash-I, New Delhi, were targeted. After the search and seizure operations, the Commissioner of Income-tax, Rohtak, issued individual notices dated January 4, 2001, to the petitioners in exercise of powers vested in him under Section 127 of th