https://www.taxtmi.com/caselaws?id=15674 Seized cash during a search under s.132 could not be treated as payment or adjustment of advance tax so as to avoid interest under ss.234B and 234C. The HC held that seizure is an act in terrorem and not a voluntary remittance; assets seized cannot be appropriated or applied towards any liability unless and until the AO passes an order under s.132(5) and thereafter applies the retained assets in accordance with s.132B. Sections 132(5) and 132B contemplate retention only to the extent of tax liability and refund of excess with statutory interest, reinforcing that seizure does not constitute advance tax payment. Consequently, the assessee remained liable for interest under ss.234B/234C; the Tribunal's contrary view was set aside and the petitions were dismissed. en-us Wed, 21 Apr 1999 00:00:00 +0530 Fri, 19 Dec 2025 16:02:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=15674 Seized cash during a search under s.132 could not be treated as payment or adjustment of advance tax so as to avoid interest under ss.234B and 234C. The HC held that seizure is an act in terrorem and not a voluntary remittance; assets seized cannot be appropriated or applied towards any liability unless and until the AO passes an order under s.132(5) and thereafter applies the retained assets in accordance with s.132B. Sections 132(5) and 132B contemplate retention only to the extent of tax liability and refund of excess with statutory interest, reinforcing that seizure does not constitute advance tax payment. Consequently, the assessee remained liable for interest under ss.234B/234C; the Tribunal's contrary view was set aside and the petitions were dismissed. Case-Laws Income Tax Wed, 21 Apr 1999 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=15674