Seized cash eligible for appropriation against interest liability U/s. 234A

Nitin Kumar Vs ACIT (ITAT Kolkata) Interest under section 234A is charged for delay in filing of the return from the prescribed due date. The cash was seized from the possession of the assessee before due date of filing of return under section 139(1) in the relevant assessment year when such seizure took place. Thus, it could be safely concluded that revenue was in possession of the seized cash from the date of such seizure for adjustment towards existing liability of the assessee. Therefore, the tax payable by the assessee on the returned income was eligible for appropriation from the seized ...