Refund Interest on Seized Cash: delay after search cannot be excused by absence of assessment

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....Section 132B(4) requires simple interest on refundable seized cash from the day after expiry of 120 days from the last authorisation, and the Revenue cannot defeat that liability by relying on its own failure to complete assessment. Where refund is unduly delayed and no assessment has been made, Article 226 may support compensatory relief beyond the statutory framework. A pending vigilance reference does not justify withholding or postponing interest. The respondents were directed to pay interest on the refunded cash at the statutory rate until refund, with enhanced interest if payment was further delayed.....