Delay and laches bar interest claim on seized cash under the Income-tax seizure and retention scheme.

A writ seeking interest on seized cash and further interest until payment was rejected as stale because the petitioner approached the Delhi High Court years after the assessment proceedings and appellate order. The seized assets were governed by section 132 and the retained assets by section 132B of the Income-tax Act, which contemplates return of surplus assets and interest only within the statutory period specified. As no prompt request for release was made and no material showed any legal restraint on release, the Court held the claim barred by delay and laches and declined to entertain the additional interest claim.

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Issues: Whether the writ petition seeking interest on seized cash and further interest till payment was liable to be entertained in view of the delay in approaching the Court.

Analysis: The seized amount was dealt with under section 132 of the Income-tax Act, 1961, and the retained assets were governed by section 132B. The Court noted that the petitioner did not seek release or return of the amount within a reasonable time after the assessment proceedings and the appellate order, and no material showed any restraint on release of the seized amount. The statutory scheme under section 132B contemplated return of surplus assets and payment of interest only for the period specified therein. Since the writ petition was filed years later, the claim was considered stale.

Conclusion: The petition was barred by delay and laches and was not entertained; the claim for additional interest failed.

Ratio Decidendi: A writ seeking refund-related relief under the seizure and retention provisions of the Income-tax Act, 1961 will not be entertained when the petitioner approaches the Court after an inordinate and unexplained delay beyond a reasonable period from the accrual of the right.

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