2011 (9) TMI 97

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....l is admitted on the following reframed question of law: Whether the ITAT was justified in holding that the seized cash amounting to Rs. 18,00,000/and the amount of Rs.1.98 Crores deposited by the Assessee on 31st January, 2007 could be adjusted against the Advance Tax liability while computing the interest under sections 234B and 234C of the Income Tax Act, 1961? 2 The Appeal is taken up for f....

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....see be adjusted towards the advance tax payable on the additional income declared by the Assessee during the course of search. It is not in dispute that the additional income offered by the Assessee has been accepted and the assessment order has been passed accordingly. However, while computing interest under sections 234B and 234C of the Income Tax Act, 1961, the Assessing Officer declined to tak....

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....he Acts set out therein. In the present case, the tax liability relating to the assessment year in question would get crystalised only after the assessment is completed and therefore, the request of the assessee for adjustment of the amounts in question towards the advance tax liability could not be entertained. 8 We see no merit in the above contention, because, once the assessee offers to tax....