Recording reason to believe in INS-01 is a pre-requisite to initiate Search
The Hon’ble Allahabad High Court in the case of Excellentvision Technical Academy (P.) Ltd. held that where Revenue department failed to put forward the actual reasons to believe as required under Section 67 of the CGST Act, 2017 before initiating search, in such case the entire proceedings is liable to be quashed.
