2010 (9) TMI 771

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..... ion of the following substantial question of law :   "Whether the amount seized at the time of search under section 132 can be adjusted towards the advance tax liability of the year during which search had been conducted ?"   2. Briefly the facts necessary for deciding the appeal as culled out from the record are that a search was conducted at the business premises of the assessee on J .....

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..... to Rs. 1,04,412 and Rs. 1,47,024 under sections 234A and 234B was charged. Being aggrieved, the assessee filed appeal against deduction made and also charging of interest under sections 234A and 234B before the Commissioner of Income-tax (Appeals) (in short "the CIT(A)") who vide order dated January 5, 1996, deleted the interest charged under sections 234A and 234B of the Act. Feeling dissatisfied .....

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..... rom the date of making the application in that regard. In the present case, the assessee had made request for adjustment of the advance tax liability of Rs. 3,14,312 against the seized amount of Rs. 5,90,000 on August 28, 1989. Since the first instalment of advance tax was payable on September 15, 1989 and the request for adjustment having been made on August 28, 1989 and reminder on September 12, .....

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