Summarize the following court judgment. ition No. 96 of 1972. Under Article 32 of the Constitution of India. I. N. Shroff for the appellant/petitioner. B. B. Ahuja and section P. Nayar for respondents. The Judgment of the Court was delivered by SHINGHAL J. This is a petition under article 32 of the Constitution. Bhupendra Ratilal Thakkar	 petitioner No. 1	 is the managing partner of the other petitioner M/s Rajnikant Nareshchandra Shroff	 which is a partnership firm carrying on the business of "shroffs and bankers". Its principal place of business is said to be at Mehmadabad	 with branches at Surat and Bombay. The petitioners applied for registration of the firm on April 7	 1971	 and had time to file their return of income upto June 30	 1972. It has been claimed that the firm had large sums of money in cash as well as 'hundis ' and other bills of exchange which formed its stock in trade and that there was no justification for thinking that it would not do what was required to be done under the law relating to income tax. The firm had a sum of Rs. 12	00	000/ as cash on January 10	 1972	 which is said to have been duly entered in its books of account in the Bombay branch office. The grievance of the petitioners is that some of the 892 respondents entered these premises on January 10	 1972	 "in purported exercise of the powers conferred by section 132"	 and seized the sum of Rs. 12	00	000/ along with the books of account and other documents. Searches are also said to have been carried out in Mehmedabad office and the branch office at Surat	 and some more books of account	 papers and documents are said to have been seized there. The petitioners have stated that as the sum of Rs. 12	00	000/ was the stock in trade of the firm	 and it had not been secreted	 there was no justification for the seizure of the money or the books and the other documents. They have accordingly stated that the seizure was an abuse of the authority conferred by sections 132 and 132 A of the Income tax Act	 1961	 hereinafter referred to as the Act	 and rules 112	 112 A	 112 B	 112 C and 112 D of the Income tax Rules	 1962	 hereinafter referred to as the Rules. The petitioners have contended that sections 132 and 132 A of the Act are unconstitutional because they are violative of articles 14	 19(1)(f) and (g) and 31(1) of the Constitution. It has also been urged that the aforesaid rules are illegal as they are not backed by any legal authority. The aforesaid provisions have also been challenged on the ground that they are violative of article 14. In regard to sections 132 and 132 A of the Act	 the petitioners have further stated that they should be struck down as they confer naked	 arbitrary	 unguided	 discriminatory and uncanalised power on the executive authority. The petitioners have also prayed for the restoration of the property which has been seized by the income tax authorities. It has been pointed out in the petition that three similar writ petitions were pending in this Court	 including writ petition No. 446 of 1971. Pooran Mal vs Director of Inspection Investigation. The respondents have admitted the search and the seizure of the property	 but have stated that this was done because the Commissioner of Income tax	 Gujarat I	 respondent No. 1	 had reasons to believe that the petitioners would not produce their books of account etc. even though they would be useful to the department for taking proceedings under the Act. It has also been stated that there was enough material before the Commissioner for exercising the power under section 132(1) of the Act. The respondents have made specific averments in this connection including the averment that books of account were unreliable	 and that the claim that the sum of Rs. 12	00	000/ was shown as balance in the books of account was incorrect. They have also denied the allegation that any search was carried on in the Mehmedabad head office of the petitioner firm or that the sum of Rs. 12	00	000/ was kept as the firm 's stock in trade or that the firm was left with no other money whatsoever. The petitioners ' contention against the legality of sections 132 and 132 A of the Act and the Rules has also been controverted. It will be recalled that in their writ petition the petitioners have made a specific reference to Pooran Mal 's writ petition No. 446 of 1971. That case has been heard and decided by this Court on December 14	 1973 and the decision has been reported in Pooran Mal 893 etc. vs Director of Inspection (Investigation) of Income Tax	 New A Delhi and others Mr. Shroff has frankly conceded that the points which have been raised in this petition have been considered in that case	 and that he has nothing to say in regard to the validity of sections 132 and 132 A of the Act and rules 112 and 112 A of the Rules or the averments in the petition in that connection. In fact it has been held by this Court in Pooran Mal 's case that "it was impossible to hold that the impugned provisions were violative of articles 14	 19 or 31. " All that Mr. Shroff has argued is that the validity of rules 112 B and 112 C of the Rules was not the subject matter of examination in Pooran Mal 's case and that it would be necessary for this Court to examine that part of the controversy	 as and when it is permissible to do so	 with reference to the provisions of article 14 of the Constitution. We have gone through rules 112 B and 112 C of the Rules. Rule 112 B relates to the release of the articles seized under section 132(5) of the Act	 and merely provides that where	 in pursuance of that section	 any assets or part thereof have to be released	 the Income tax officer shall forthwith deliver the same to the person from whom custody they were seized. Rule 112 C provides for the release of the remaining assets	 and it is to the effect that they shall be made out or paid to the person from whose custody they were seized	 after the discharge of the liabilities referred to in cl (i) of sub section (1) of section 132 A of the Act. Both these are therefore beneficial rules	 and there can be no satisfactory reason for challenging their validity with reference to article 14 of the Constitution. So when the present case is not different from Pooran Mal 's case	 there is no merit in this writ petition. It is hereby dismissed. There will however be no order as to costs. P.H.P. Petition dismissed.

The petitioners carry on business as Shroffs and Bankers. The Income tax Department searched various premises of the petitioners and seized a sum of Rs. 12 lakhs in cash from the petitioners	 under section 132 and 132A of the Income tax Act. The petitioners contended that the said amount represented the stock in trade of the petitioners. The petitioners also contended that the provisions of section 132 and 132A of the Income tax Act	 1961	 as well as rules 112	 112A	 112B and 112C of the Income Tax Rules	 1962	 were unconstitutional as violative of Article 14	 19(1)(f) and (g) and 31(1) of the Constitutional. Section 132 and 132A were further challenged on the ground of conferring naked	 abitrary	 unguided	 discriminatory and uncanalised power on the executive authority. Dismissing the petition	 ^ HELD: (1) This Court has already upheld in Pooran Mal 's case the validity of section 132 and 132A as well as rules 112 and 112A. [893 A & C] (2) Rules 112B and 112C relate to the release of the articles seized and are therefore beneficial rules and as such cannot be challenged. [893D]