One of the questions that arises for our consideration is whether in thepresentcase, the provisions of s. 132(1)(c) the Act were satisfied, or not, before authorizing the search. On a perusal of the satisfaction note as well as the counter-affidavit on behalf of respondent Nos. 3 and 4, it is evident that the sole ground for the action of search and seizure is that the Investigation Wing of the IT Department was in possession of credible information that petitioner was in possession of jewellery which represents his undisclosed income or property. Apart from mere reproduction of the said words, no cogent basis for arriving at this conclusion is discernible from the satisfaction note. There is plethora of case law holding that the term "reason to believe" cannot be interpreted and construed as "reason to suspect". The reason to suspect that the petitioner has undisclosed assets, and that there is likelihood that the same would not be disclosed, does not amount to saying that there are reasons to believe that the petitioner is in possession of undisclosed assets, and intends to evade tax.