Seized Cash Cannot Be Adjusted Against Advance Tax But May Qualify for Self-Assessment Tax Adjustment u/s 132B.

During a 2014 search operation, seized cash adjustment against advance tax liability was denied per Section 132B and Explanation 2. ITAT held that while self-assessment tax qualifies as 'existing liability', the assessee failed to include seized cash in total income computation. The matter of adjusting seized cash against self-assessment tax was remanded to AO for verification of circumstances similar to precedent case. Regarding interest u/s 220, ITAT ruled the assessee cannot be deemed in default as seized cash was already with Department within 30-day notice period. AO directed to adjust seized cash against tax liability if self-assessment tax adjustment relief is denied post verification. .....

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