Search seizure refund interest follows section 132B, not general refund-interest rules, for delayed release of seized assets.

Where assets are seized in a search under section 132 of the Income-tax Act, delayed-refund interest is governed by the specific scheme in section 132B, not by the general refund-interest provision in section 244A(1)(b). The High Court held that section 132 is a self-contained code for retention, adjustment and refund of seized assets, and that section 132B(4) alone governs any entitlement to simple interest on late refund. The claim under section 244A(1)(b) was therefore rejected, and the writ was dismissed in favour of the Revenue.

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Issues: Whether interest on assets seized in a search under section 132 of the Income-tax Act, 1961 could be claimed under section 244A(1)(b), and whether the claim was instead governed by section 132B(4).

Analysis: A search and seizure under section 132 is treated as a self-contained scheme for dealing with seized assets. The statutory mechanism for retention, adjustment and refund of such assets is found in section 132B, and section 132B(4) specifically provides for simple interest where the retained amount is refunded late. Since the claim arose from seized assets under section 132, the general interest provision in section 244A(1)(b) was held to have no application. The entitlement, if any, had to be examined only within the framework of section 132B(4)(a) and (b).

Conclusion: The claim for interest under section 244A(1)(b) was rejected, and the writ was dismissed in favour of the Revenue.

Ratio Decidendi: Where assets are seized in a search under section 132, interest on delayed refund is governed by the specific scheme in section 132B and not by the general refund-interest provision in section 244A(1)(b).

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