SHEONATH PRASAD & ORS. vs STATE OF BIHAR

The Supreme Court held that the Superintendent of Commercial Taxes lawfully exercised powers under Section 17 of the Bihar Sales Tax Act, 1947, to inspect and seize accounts from a place where the dealer kept records, which qualifies as a 'place of business' under Section 2(1). The Court ruled that the powers of inspection are not restricted to places declared by the dealer and that the provisions of Section 165(4) and Section 103 of the Criminal Procedure Code do not apply as the Superintendent was not investigating a cognizable offence. The High Court's conviction of the appellants for dacoity under Section 395 IPC was upheld, affirming the legality of the search and seizure.