https://www.taxtmi.com/caselaws?id=449997 ITAT Rajkot held that AO failed to adjust seized cash and FDRs against existing tax liability within prescribed 120-day period following search operations. The court found that since seized assets were from disclosed income sources and no additions were made during assessment, AO should have adjusted Rs. 5,39,000 cash and Rs. 99,99,999 FDRs against tax liability of Rs. 6,39,620. Interest under section 234B was improperly levied beyond the 120-day statutory period. However, the tribunal rejected assessee's claim for interest on seized FDRs under section 132B(4), ruling that FDRs constitute "other valuable articles" rather than "money" and therefore do not qualify for interest compensation. Appeals partially allowed for statistical purposes. en-us Wed, 31 Jan 2024 00:00:00 +0530 Sat, 24 Feb 2024 09:27:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=449997 ITAT Rajkot held that AO failed to adjust seized cash and FDRs against existing tax liability within prescribed 120-day period following search operations. The court found that since seized assets were from disclosed income sources and no additions were made during assessment, AO should have adjusted Rs. 5,39,000 cash and Rs. 99,99,999 FDRs against tax liability of Rs. 6,39,620. Interest under section 234B was improperly levied beyond the 120-day statutory period. However, the tribunal rejected assessee's claim for interest on seized FDRs under section 132B(4), ruling that FDRs constitute "other valuable articles" rather than "money" and therefore do not qualify for interest compensation. Appeals partially allowed for statistical purposes. Case-Laws Income Tax Wed, 31 Jan 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=449997