Retention of seized cash and jewellery was limited after appellate relief, with release directed against bank guarantee.

Cash and gold jewellery seized during search could not be retained indefinitely after the assessee's tax liability was substantially reduced in appeal, and retention under the time-bound seized-asset provision was not sustained on the stated facts. The High Court directed release of the cash and jewellery on the petitioner furnishing a bank guarantee of Rs. 75,000, while keeping the matter subject to the final order in the Department's pending appeal before the Tribunal.

---

---

Issues: Whether cash and jewellery seized during search could continue to be retained by the Department after the assessee's tax liability was substantially reduced in appeal, and whether the Department could justify retention under the provision relating to time-bound retention of seized assets pending proceedings.

Outcome: The writ petition was disposed of with a direction to return the cash and gold jewellery to the petitioner on furnishing a bank guarantee of Rs. 75,000, subject to the final order in the Department's pending appeal before the Tribunal.

---